This part of GOV.UK is being rebuilt – find out what beta means

HMRC internal manual

Company Taxation Manual

Shadow ACT: unrelieved surplus: displacement of


  • unrelieved surplus ACT set against a company’s liability is displaced,
  • the company is, as a consequence assessed or an amendment of its self assessment is made, and
  • six months from the date when the tax became due and payable or from the date when an amendment of the company’s self assessment was made, whichever is the later, the tax remains unpaid,

an assessment can be made on any other company (in the name of the affected company) that is a member of the group at any time in the relevant accounting period.

The assessment has to be within two years from the six months date and can be made for whole or part of the amount.

The company is entitled to recover an amount equal to any tax and interest that it pays from the affected company.