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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: additional claims

ICTA88/S246R (1) - (7)

A company could make a claim to repayment or set off of ACT under the FID provisions, and subsequently elect to match another FID (or another part of the FID) of the same accounting period with distributable foreign profits (DFP) of later accounting periods under ICTA88/S246J (5) or ICTA88/S246K (10). It could then make a further claim or claims to repayment or set off of ACT to take account of that later matching.

Any FID which had already been treated as a qualifying FID for the relevant period was ignored when calculating the notional surplus ACT under ICTA88/S246P (CTM21420) for the additional claim.

A company could only elect for a matched FID to be a qualifying FID to the extent that FID paid exceeded FID received (ICTA88/S246P (6), CTM21430). To the extent that an FID had already been treated as a qualifying FID, it reduced the ICTA88/S246P (6) limit for the purpose of the additional claim.