CTM04610 | Corporation Tax: trading losses - relief against total profits: restriction of relief for uncommercial trading - meaning of ‘profit’
From HM Revenue & Customs · Company Taxation Manual
In the context of CTA/S44 (see ) ‘profit’ means commercial profit. For CT purposes, ‘profit’ means ‘income and chargeable gains’, see . 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.