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.