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HMRC internal manual

Company Taxation Manual

From
HM Revenue & Customs
Updated
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ACT: FID: foreign profits: matching FID with distributable foreign profit (DFP): of same company

ICTA88/S246J (1) (2), (4), (5), & (6)

Where a company paid an FID it could elect to match all or part of that FID on a pound for pound basis with a DFP received by it.

All or part of one or more FID could be matched with all or part of one or more DFP.

An FID paid in an accounting period could be matched with a DFP of that or the immediately preceding accounting period. The company could match with DFP of those two periods as it chose.

An FID paid in an accounting period could be matched with a DFP of any subsequent accounting period if the FID could not be matched against a DFP of that or the preceding accounting period.

To show an election a company needed only match FID with DFP in its computation.

An FID paid could not be matched against all or part of a DFP more than once.