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HMRC internal manual

Company Taxation Manual

From
HM Revenue & Customs
Updated
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ACT: set-off against CT on profits: time limit

The time limit for a claim under ICTA88/S239 (3) was two years after the end of the accounting period to which the surplus related (but see CTM20250).

In the case of companies operating Lloyd’s underwriting agencies, the time limit under ICTA88/S239(3) was, by concession, extended to four years after the end of the accounting period to which the surplus related. The concession applied to accounting periods which included profit commission derived from underwriting account 1989 and earlier years or which would have included such commission had any arisen. The concession could be applied in modified form for subsequent accounting periods up to and including accounting periods ended 29 June 1991 by an extension of the time limit to 30 June 1993.