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Contents

Official guidance
Company Taxation Manual

CTM21400 · ACT: FID: repayment or set off of ACT

  • CTM21405 · Outline
  • CTM21410 · ACT already dealt with
  • CTM21420 · Notional foreign source
  • CTM21430 · Qualifying FID
  • CTM21440 · Matched foreign source profits
  • CTM21450 · Procedure
  • CTM21452 · Provisional repayment
  • CTM21455 · Evidence for repayment
  • CTM21460 · Additional claims
  • CTM21480 · Revision of profits
  1. ACT: FID: repayment or set off of ACT: contents
  2. ACT: FID: repayment or set off of ACT: matched foreign source profits

CTM21440 | ACT: FID: repayment or set off of ACT: matched foreign source profits

From HM Revenue & Customs · Company Taxation Manual

ICTA88/S246P (8), (9) & (10)

A matched foreign source profits (FSP) was an FSP underlying a matched distributable foreign profits (DFP). A matched DFP was a DFP, which was, at the time of the claim to ACT repayment or set off, matched with a qualifying FID.

Where only a proportion of a DFP had been matched with a qualifying FID, the matched FSP was the same proportion of the FSP underlying that DFP.

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