For company taxation purposes, total profits are the total of (i) the company's net income from each source (trade, property business, interests, dividends, etc.) and (ii) the company's net chargeable gains arising from the sale of capital assets. The rules governing expense deductibility vary according to the type of income the expenses relate to.
In general, all expenses that are not capital in nature and that are used for trading purposes are deductible. Local municipal taxes are generally deductible. Interest is deductible within the debt cap rules that apply to companies that are members of large groups. Most donations to charities are tax-deductible. Provisions for future costs can be deducted for tax purposes under certain conditions.The actual and deemed costs incurred by an employing company for providing shares or options to employees are usually deductible, depending on the nature of the share plan and the accounting treatment. This generally allows a subsidiary company to claim a deduction when its employees receive shares or options in the parent company.
Provisions for future costs can be tax-deductible if they involve allowable revenue expenditure, align with acceptable accounting practices, comply with statutory timing rules, and are accurately estimated. This includes bad debts on trading accounts, typically handled under 'loan relationships' rules for financing costs and income. If a bad debt meets UK accounting standards for a specific provision, it should be deductible.
Operating losses can be offset by the profits of the current fiscal year while the exceeding loss can be carried forward to the previous year. Operating losses incurred prior to 1 April 2017 can be carried forward indefinitely and offset by operating profits from future tax years. Operating losses incurred after 1 April 2017 can be offset by any type of profit. In both cases, the maximum carried forward loss offset is broadly limited to GBP 5 million plus 50% of the current year's profits in excess of that amount.
Capital losses can only be offset by capital gains and their carryback is prohibited. For accounting periods ending on or after 1 April 2020, the use of carried-forward capital losses is limited to 50% of gains above a groupwide GBP 5 million allowance per year (shared between capital and non-capital losses).
Large companies can claim a 20% "above the line" R&D credit. SMEs receive an enhanced 186% tax deduction for certain R&D expenditures, but starting 1 April 2024, this merged into the large company scheme, offering a 20% R&D credit instead. Loss-making companies will face a notional tax rate of 19% on the credit. Additionally, a separate enhanced deduction for "R&D intensive" loss-making SMEs has beene introduced retroactively from 1 April 2023.
The patent box regime allows a 10% corporation tax rate on profits from qualifying patents. Creative industry tax reliefs provide up to an additional 100% deduction for qualifying expenditures in film, animation, video gaming, high-end TV, children's TV, orchestral concerts, and theater. New legislation in 2024 will replace current audiovisual and video game expenditure credits, effective 1 January 2024, but existing regimes can be applied until 31 March 2027 for productions starting before 1 April 2025.
Businesses in designated Freeport tax and customs sites benefit from additional tax reliefs, including exemptions from SDLT and business rates, and simplified customs procedures.