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HMRC internal manual

Company Taxation Manual

ACT: FID: repayment or set off of ACT: matched foreign source profits

ICTA88/S246P (8), (9) & (10)

A matched foreign source profits (FSP) was an FSP underlying a matched distributable foreign profits (DFP). A matched DFP was a DFP, which was, at the time of the claim to ACT repayment or set off, matched with a qualifying FID.

Where only a proportion of a DFP had been matched with a qualifying FID, the matched FSP was the same proportion of the FSP underlying that DFP.