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HMRC internal manual

Company Taxation Manual

HM Revenue & Customs
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Groups: surrender of ACT: payment by subsidiary for surrender

ICTA88/S240 (8)

If a payment is made by a subsidiary to a surrendering company under an agreement between them for the surrender of ACT, and the payment does not exceed the amount surrendered, the payment is not to be:

  • taken into account in computing the profits or losses of either company for CT purposes,


  • regarded as a distribution or a charge on income.