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HMRC internal manual

Company Taxation Manual

HM Revenue & Customs
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ACT: FID: repayment or set off of ACT: provisional repayment

The amount of ACT to be repaid could not be finally quantified until the company’s CT liability for the accounting period had been settled.

However, you could make a provisional repayment of ACT to the company if you were satisfied on the basis of provisional CT computations that an amount of ACT would ultimately be repayable under the FID provisions when figures were finally agreed. Whether or not full provisional repayment could be made would have depended on the information provided to you.

Provisional repayment could not be made until nine months after the end of the accounting period concerned.

The repayment of ACT was only available after the company had made an election to match an FID with a distributable foreign profits (DFP) or eligible profit. The company would have submitted a computation in support of a claim to provisional repayment. You treated it as an election to match the FID with the DFP or eligible profit concerned. This was to be pointed out to the company before making the provisional repayment.