CTM01110 | Corporation Tax: introduction: definition of company profits

From HM Revenue & Customs · Company Taxation Manual

The profits of a company resident in the UK which are chargeable to CT for any accounting period are:

  • its income for that accounting period, except

    • distributions which are exempt by virtue of (see below - this in essence exempts domestic distributions received, as well as many foreign distributions),

    plus

    • its chargeable gains for that period.

    So, for CT, ‘income’ and ‘profits’ are not interchangeable terms.

    deals with the treatment of distributions in the hands of a company recipient. It covers both domestic and foreign distributions received, and exempts them with certain limited exceptions. It was introduced by as part of the major change in treatment of foreign distributions. Previously the exemption for domestic distributions was at ICTA88/S208, which was briefly before came into effect.