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HMRC internal manual

Company Taxation Manual

ACT collection: amount of set-off: different rates

ICTA88/S246 (5)

A limit is imposed by ICTA88/S239 (2) on the amount of ACT to be set off (see CTM20150). This limit will be affected if different rates of ACTapply for different parts of an accounting period. ICTA88/S246 (5) deals with this.

You should arrive at the limit as follows:

  • The profits of the accounting period are apportioned between the different parts on a time basis.
  • The apportionment is made to and from 31 March and not to and from 5 April.
  • The maximum ACT that can be set off for each part is then calculated as if each part were a separate accounting period. The maximum amount of ACT which can be set off for the whole accounting period is arrived at by aggregating these separate amounts.