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HMRC internal manual

International Manual

Reliefs against Controlled Foreign Companies' tax: ‘Relevant amount’

Where an apportionment is made on a United Kingdom company which, for the year for which the company is assessed in respect of those profits, has an amount of surplus shadow ACT available for set-off against its corporation tax liability (this includes Chapter IV tax), it must set that amount against its Chapter IV liability to the extent that it does not exceed the relevant maximum.

The amount of unrelieved surplus ACT that can be set-off against the Chapter IV liability is limited to the difference - referred to in regulation 20 as ‘the relevant amount’ - between the ‘relevant maximum’ and the surplus shadow ACT set against the Chapter IV liability.