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HMRC internal manual

Company Taxation Manual

ACT: FID: international headquarters companies (IHC): company found not to be an IHC

ICTA88/S246T and ICTA88/S246V

A company was not liable to pay ACT in respect of an FID paid in an accounting period if at the time of payment the company treated itself as an IHC.

If the company was found ultimately not to be an IHC in the accounting period, the rule that such a company was not liable to pay ACT in respect of an FID was treated as never having applied. The rules concerning the repayment or set off of ACT in ICTA88/S246N and ICTA88/S246Q (CTM21405) then applied as if the company had not treated itself as an IHC at any time in the accounting period of payment.

See also CTM22360 concerning assessments to collect ACT.