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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: computation of: company ceasing to be a member of a group

CTM18600 | Shadow ACT: computation of: company ceasing to be a member of a group

From HM Revenue & Customs · Company Taxation Manual

SI1999/358 reg11 (7)

Where a company ceases to be a member of a group, shadow ACT is computed as if the part of the accounting period (AP) before it ceased to be a member and the part after were two separate APs.

Example

Accounting Period 1.1.2005 – 31.12.2005

Company makes a distribution of £8,000. It receives a dividend from a non-associated company which, with the tax credit, totals £32,000. It has surplus franked investment income (FII) brought forward of £20,000.

Accounting Period 1.1.2006 – 31.12.2006

Company pays a dividend of £80,000. It receives a dividend from a non-associate, which with the tax credit totals £24,000.

Accounting Period 1.1.2005 – 31.12.2005 (calculation of surplus FII)

Surplus FII brought forward£20,000
FII £32,000 x 9/8£36,000
Total£56,000
Less distribution£8,000
Plus shadow ACT£2,000
Franked distribution£10,000
Surplus FII£46,000

Accounting Period 1.1.2006 – 31.12.2006 (calculation of shadow ACT)

Distribution£80,000
Shadow ACT thereon£20,000
Franked distribution£100,000
FII £24,000 x 9/8£27,000
Plus surplus FII£46,000
£73,000
Excess£27,000

Shadow ACT is 25 per cent of the amount which, when the shadow ACT is added to it, is equal to the excess = £5,400.

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