CTM04610 - Corporation Tax: trading losses - relief against total profits: restriction of relief for uncommercial trading - meaning of ‘profit�

CTA10/S44

In the context of CTA/S44 (see CTM04600) ‘profit� means commercial profit.  For CT purposes, ‘profit� means ‘income and chargeable gains�, see CTM01110. But what S44 is concerned with is the commercial or accounting profit, disclosed by accounts which present a ‘true and fair view�.  This normally means the GAAP profits after depreciation and so on, but not taking account of capital allowances or any other tax allowance.