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.