SolvedCTM04610 | 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 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.