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HMRC internal manual

Company Taxation Manual

ACT: FID: general: election: ICTA88/S247 (1) election already in place

ICTA88/S246A (10)

Before the ACT on a FID could be repaid it had first to have been paid to the Collector. That raised the question - what happens when there is an ICTA88/S247 (1) election in place so that dividends are paid without paying ACT?

The FID election also acted as an ICTA88/S247 (3) notice so ICTA88/S247 (1) did not apply and ACT was paid. However:

  • if the FID election was revoked, the deemed ICTA88/S247 (3) notice was also treated as revoked and as never having been made,
  • the deemed ICTA88/S247 (3) notice could only be revoked by the revocation of the FID election (again to prevent a company achieving payment of an FID without ACT).