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Contents

Official guidance
Company Taxation Manual

CTM20050 · ACT: General

  • CTM20055 · Distributions
  • CTM20060 · Franked payments
  • CTM20065 · Rate of ACT
  • CTM20070 · Qualifying and non-qualifying distributions
  • CTM20075 · Bonus issue of securities or redeemable shares
  • CTM20080 · Bonus issue of shares - repayment of share capital
  • CTM20085 · Repayment of shares and securities
  • CTM20090 · Ultra vires dividends
  • CTM20095 · Notes on company law aspects of dividends
  1. ACT: General: Contents
  2. ACT: General: Franked payments

CTM20060 | ACT: General: Franked payments

From HM Revenue & Customs · Company Taxation Manual

ICTA88/S238 (1), (1A), (3), (5), ICTA88/S14 (1), (2), and (3), ICTA88/S241

A franked payment was:

  • the amount or value of a qualifying distribution other than a Foreign Income Dividend (FID), plus

  • the ACT on the distribution.

The rate of ACT used was the rate in force for the financial year in which the distribution was made, see CTM20065.

FIDs were subject to different rules and did not give rise to franked payments.

Where the franked payments made by a company in any accounting period (AP) exceeded the franked investment income (CTM16120) received by it in that period, the company was liable to pay ACT. The ACT was calculated by reference to the amount of that excess, CTM22060.

Franked investment income used to cover franked payments for the purpose of arriving at the ACT payable was described as being used to frank distributions.

It was not possible to frank a distribution if the tax credit attached to the franked investment income had been paid to the company. If the franked investment income had been used in this way, it was not taken into account in determining whether the company had an excess of franked investment income over franked payments.

Where the franked investment income received in any AP exceeded the franked payments made in that accounting period, the surplus was carried forward and treated as received in the next AP. This surplus could then be used in computing the ACT due on franked payments made in the next AP. When working out this surplus, franked investment income that could not be used to frank was excluded.

The excess of franked investment income over franked payments could also be subject to

  • a claim under ICTA88/S242 (set-off of losses and so forth against surplus franked investment income, see CTM16200,

  • a claim under ICTA88/S243 (set-off of loss brought forward or terminal loss, see CTM16200).

ICTA88/S242 and ICTA88/S243 were repealed by F(2)A97 for any accounting period beginning on or after 2 July 1997.

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