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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: accounting periods to which the Regulations apply: group members: unrelieved surplus ACT available for set off exhausted

CTM18500 | Shadow ACT: accounting periods to which the Regulations apply: group members: unrelieved surplus ACT available for set off exhausted

From HM Revenue & Customs · Company Taxation Manual

The 'relevant accounting period' for a company that is a member of a group is the first accounting period of the company after which no amount of unrelieved surplus ACT belonging to it or any other company that is a member at any time in that accounting period is available for set off. For this purpose, any amount that is set against another company's liability is regarded as available to the end of its accounting period. For example, a company makes up its accounts for the year to 31 December. The final amount of unrelieved surplus ACT is set against the liability of another group member for its accounting period ending on 31 March 2002. The company's relevant accounting period will be that for the year ended 31 December 2002.

The 'final accounting period' for the group is the accounting period beginning in the period of twelve months immediately following the end of the relevant accounting period or, if there is more than one, the latest accounting period beginning in that period.

Where surplus shadow ACT is carried back and displaces unrelieved surplus ACT revealing that period as not being the 'relevant accounting period', the later accounting period is not the 'final accounting period' and the regulations continue to apply.

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