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HMRC internal manual

International Manual

HM Revenue & Customs
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Reliefs against Controlled Foreign Companies' tax: Set-off of unrelieved surplus ACT

Any unrelieved surplus ACT is available for set-off against Controlled Foreign Companies’ tax in accordance with regulation 20 of the Corporation Tax (Treatment of Unrelieved Surplus Advance Corporation Tax) Regulations 1999. No claim is required.