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HMRC internal manual

Company Taxation Manual

ACT: set-off against CT on profits: double taxation relief

ICTA88/S797 (4) & (5)

Double taxation relief was given in priority to ACT for accounting periods beginning on or after 3 June 1986.

The rules in Section 797 (4) and (5) ensured that the limit imposed by ICTA88/S239 (2) on the maximum ACT set-off was applied separately to the foreign taxed and non-foreign taxed income or gains.

For detailed guidance on the interaction of ACT and double taxation relief see INTM167000 onwards.