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HMRC internal manual

International Manual

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HM Revenue & Customs
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Controlled Foreign Companies: legislation - introduction and outline: ACT

Where a company has unrelieved surplus ACT as at 6 April 1999 it may set it against a Chapter IV liability which could not be covered by the reliefs referred to in the preceding paragraph. The amount of ACT which may be set off is limited to a ‘relevant maximum’. Further details are given at INTM256170 to INTM256200.