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HMRC internal manual

COTAX Manual

HM Revenue & Customs
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CT Pay and File: claims / reliefs: ACT: surrender surplus ACT caused by loss carry-back

Any ACT set-off in an AP, that is displaced by a carry-back, remains effective when you calculate the amount of tax that attracts late payment interest under S87A(6) TMA 1970.

Note: This is not the case if the company claims to surrender the displaced ACT set-off to another group company under S240 ICTA 1988.

Interest is calculated as if the displaced amount had never existed.

There is no need to intervene in such cases, as COTAX calculates the EDP (Word 41KB) without regard to displaced reliefs.

See COM153051 for legislation applying to this subject.