COM153050 - CT Pay and File: claims/reliefs: Advance Corporation Tax (ACT): surrender surplus ACT caused by loss carry-back
Any Advance Corporation Tax (ACT) set-off in an Accounting Period (AP), that is displaced by a carry-back, remains effective when you calculate the amount of tax that attracts late payment interest under Section 87A(6) (S87A(6)) Taxes Management Act (TMA) 1970.
Please note that: This is not the case if the company claims to surrender the displaced ACT set-off to another group company under S240 Income and Corporation Taxes Act (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 (see Glossary for more information) without regard to displaced reliefs.
See COM153051 for legislation applying to this subject.