CTM04610 - Corporation Tax: trading losses - relief against total profits: restriction of relief for uncommercial trading - meaning of 鈥榩rofit鈥�
CTA10/S44
In the context of CTA/S44 (see聽CTM04600) 鈥榩rofit鈥� means commercial profit.聽 For CT purposes, 鈥榩rofit鈥� means 鈥榠ncome and chargeable gains鈥�, see CTM01110. But what S44 is concerned with is the commercial or accounting profit, disclosed by accounts which present a 鈥榯rue and fair view鈥�.聽 This normally means the GAAP profits after depreciation and so on, but not taking account of capital allowances or any other tax allowance.