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HMRC internal manual

Company Taxation Manual

ACT: FID: repayment or set off of ACT: revision of profits

ICTA88/S246X (1) - (3)

ACT could be set off or repaid under ICTA88/S246N, or payment made to the company under the international headquarters company reckoning provisions (CTM21550), and a subsequent event might result in the computation needing revision. For example:

  • the company might obtain less by way of group relief than was originally claimed resulting in a reduction in the amount of repayable ACT,
  • there might be an unforeseen change in the overseas tax suffered on foreign profits, so that the amount of distributable foreign profits (DFP) included in the calculation was incorrect.

The company could revise some elections where:

  • set off, payment or repayment had been made under the FID provisions,


  • there was either an alteration in a company’s profits or in overseas tax payable, which resulted in the set off payment, or repayment being incorrect.

In these circumstances the company could revise any matching election, or qualifying FID election in such manner as was just and reasonable, and any calculation relating to the FID provisions could be adjusted as was just and reasonable.