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CTM21520 | ACT: FID: international headquarters companies (IHC): whether company is an IHC

From HM Revenue & Customs · Company Taxation Manual

ICTA88/S246S (9)

Where a company paid an FID, it could treat itself as an IHC if:

  • at the time the dividend was paid the company was of the opinion it was likely to be an IHC in the accounting period in which the dividend was paid, and

  • where the dividend was paid other than in the company’s first accounting period, it was an IHC in the immediately preceding accounting period (but see CTM21510, second condition).