Corporation Tax Act 2010 section 269ZF

"Relevant trading profits", "total relevant non-trading profits" etc.

Section 269ZF defines how to calculate relevant trading profits, relevant non-trading income profits, relevant chargeable gains, and total relevant non-trading profits for the purposes of the corporate loss restriction rules.

• Relevant trading profits, relevant non-trading income profits and relevant chargeable gains are each calculated by deducting the applicable deductions allowance from the corresponding qualifying profits or gains, with a floor of nil
• Total relevant non-trading profits combine qualifying non-trading income profits and qualifying chargeable gains, less the total non-trading profits deductions allowance
• Qualifying profits and gains are determined through a five-step process that starts with modified total profits, identifies reliefs available against those profits, splits them into trading profits, non-trading income profits and chargeable gains, and then allocates the reliefs across those categories
• Certain types of income and deductions are excluded from the calculation, including company distributions, oil ring fence profits, insurance company I-E profits, carried-forward capital losses, and various specified carried-forward amounts