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HMRC internal manual

Company Taxation Manual

ACT: set-off against CT on profits: surplus ACT

As a result of ICTA88/S239 (2) the whole of the ACT available may not have been set-off against the CT chargeable for the accounting period in which the distributions were made. The unused ACT was described as surplus ACT for that accounting period.

Surplus ACT resulting from an FID paid could be set-off or repaid in certain circumstances(CTM21010). Surplus ACT was otherwise dealt with as described in CTM20170 onwards.