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HMRC internal manual

Company Taxation Manual

ACT: FID: repayment or set off of ACT: evidence for repayment

Before making a repayment of ACT under the FID scheme you needed to receive sufficient evidence to satisfy you on the following matters:

  • that the ACT had been paid,
  • the existence of sufficient foreign source profits,
  • those foreign source profits were likely to have been sufficiently taxed overseas.

Responsibility for agreeing figures for double taxation relief lay with FICO. However that need not have prevented you from making a provisional repayment of ACT under CTM21452 if you expected that ACT to ultimately be repayable.