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Official guidance
Company Taxation Manual

CTM18000 · Shadow ACT to 31 March 2026

  • CTM18200 · Shadow ACT: set-off of ACT: accounting periods ending on or before 5 April 1999
  • CTM18210 · Shadow ACT: set-off of ACT: accounting periods beginning before and ending after 5 April 1999
  • CTM18220 · Shadow ACT: set-off of ACT: accounting periods beginning on or after 6 April 1999
  • CTM18230 · Shadow ACT: unrelieved surplus ACT
  • CTM18250 · Shadow ACT: outline of the scheme
  • CTM18260 · Shadow ACT: companies to which the regulations apply
  • CTM18300 · Shadow ACT: definition of a group
  • CTM18320 · Shadow ACT: definition of parent and subsidiary companies
  • CTM18350 · Shadow ACT: definition of a group: additional tests for 51% subsidiaries
  • CTM18360 · Shadow ACT: definition of a group: additional tests for parent companies
  • CTM18370 · Shadow ACT: definition of a group: arrangements
  • CTM18400 · Shadow ACT: accounting periods to which the Regulations apply: company not a member of a group: immediate opt out
  • CTM18420 · Shadow ACT: accounting periods to which the Regulations apply: company not a member of a group: no immediate opt out
  • CTM18430 · Shadow ACT: accounting periods to which the Regulations apply: company not a member of a group: unrelieved surplus ACT available for set off exhausted
  • CTM18450 · Shadow ACT: accounting periods to which the Regulations apply: company not a member of a group: later opt out
  • CTM18470 · Shadow ACT: accounting periods to which the Regulations apply: group members
  • CTM18480 · Shadow ACT: accounting periods to which the Regulations apply: group members: immediate opt out
  • CTM18500 · Shadow ACT: accounting periods to which the Regulations apply: group members: unrelieved surplus ACT available for set off exhausted
  • CTM18510 · Shadow ACT: accounting periods to which the Regulations apply: group members: later opt out
  • CTM18550 · Shadow ACT: computation of: introduction
  • CTM18570 · Shadow ACT: computation of: subsidiary with election under Regulation 11(3)
  • CTM18580 · Shadow ACT: computation of: surplus franked investment income
  • CTM18590 · Shadow ACT: computation of: distributions outside an accounting period
  • CTM18600 · Shadow ACT: computation of: company ceasing to be a member of a group
  • CTM18650 · Shadow ACT: utilisation of: overview
  • CTM18670 · Shadow ACT: utilisation of: Double Taxation Relief
  • CTM18680 · Shadow ACT: utilisation of: carry back
  • CTM18700 · Shadow ACT: utilisation of: allocation of surplus within groups
  • CTM18710 · Shadow ACT: utilisation of: companies leaving and joining a group
  • CTM18720 · Shadow ACT: unrelieved surplus: set-off
  • CTM18730 · Shadow ACT: unrelieved surplus: restriction on set- off of arising as the result of a surrender
  • CTM18750 · Shadow ACT: unrelieved surplus: ACT buying
  • CTM18760 · Shadow ACT: unrelieved surplus: change of ownership of company
  • CTM18770 · Shadow ACT: unrelieved surplus: asset transferred after change in ownership of company
  • CTM18800 · Shadow ACT: unrelieved surplus: recovery of ACT wrongly set off
  • CTM18810 · Shadow ACT: unrelieved surplus: displacement of
  • CTM18850 · Shadow ACT: controlled foreign companies liabilities
  1. Shadow ACT to 31 March 2026: contents
  2. Shadow ACT: set-off of ACT: accounting periods ending on or before 5 April 1999

CTM18200 | Shadow ACT: set-off of ACT: accounting periods ending on or before 5 April 1999

From HM Revenue & Customs · Company Taxation Manual

ICTA88/S239 (2)

The ACT available for set-off against a company's liability for an accounting period is the total of any ACT:

  • paid in respect of any distribution made in the accounting period,

  • any surplus carried forward from the previous accounting period under S239 (4),

  • any amount surrendered to the company under S240 (1), and

  • any amount carried back under S239 (3) from an accounting period beginning before 6 April 1999.

The amount of the set-off is limited to an amount equal to the ACT that would have been payable in respect of a distribution made at the end of the period of an amount which, together with the ACT thereon, is equal to the company's CT profit for the accounting period.

Guidance on the regime for accounting periods ending before 6 April 1999 can be found at CTM20000 onwards.

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