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ICTA88/S246N - R, ICTA88/S246N (1), (2), (3) (4), & (7)

Once a company had matched an FID paid with a distributable foreign profit (CTM21310), the amount of ACT which could be repaid or set off had to be calculated.

»Ê¹ÚÌåÓýapp guidance up to CTM21460 only applied where a company did not treat itself as an international headquarters company at any time in the accounting period in which the FID was paid (the ‘relevant periodâ€�). Where a company did treat itself as an international headquarters company at any time in that accounting period see CTM21505.

Where a company had paid ACT - the ‘relevant ACTâ€� - in respect of qualifying distributions made by it in the relevant period, see CTM21340, an amount of ACT was repaid or set off. »Ê¹ÚÌåÓýapp amount was the smaller of the ACT which:

• had not already been dealt with (used in some way, CTM21410),
• would be surplus if certain assumptions were made (CTM21420).

No amount was repaid or set off unless the company made a claim. See also CTM21450 regarding claims on returns.