CTM80330 - Groups: group relief: meaning of non-UK profits

ICTA88/S403D (3) and (4), ICTA88/S403E (7)

For the purposes of group relief in respect of the losses of permanent establishments ( CTM80310) and determining whether tax relief is available in an overseas jurisdiction ( CTM80315) ‘non-UK profits’ means any amount:

• which is, or is taken into account in computing, profits income or gains on which foreign tax is charged, and
• which is not, or is not taken into account in computing, UK profits chargeable to CT for any accounting period.