CTM21405 | ACT: FID: repayment or set off of ACT: outline

From HM Revenue & Customs · Company Taxation Manual

ICTA88/S246N - R, ICTA88/S246N (1), (2), (3) (4), & (7)

Once a company had matched an FID paid with a distributable foreign profit (), the amount of ACT which could be repaid or set off had to be calculated.

The guidance up to only applied where a company did not treat itself as an international headquarters company at any time in the accounting period in which the FID was paid (the ‘relevant period’). Where a company did treat itself as an international headquarters company at any time in that accounting period see .

Where a company had paid ACT - the ‘relevant ACT’ - in respect of qualifying distributions made by it in the relevant period, see , an amount of ACT was repaid or set off. The amount was the smaller of the ACT which:

  • had not already been dealt with (used in some way, ),

  • would be surplus if certain assumptions were made ().

No amount was repaid or set off unless the company made a claim. See also regarding claims on returns.