CTM21410 - ACT: FID: repayment or set off of ACT: ACT already dealt with

ICTA88/S246N (5) & (6)

ACT had already been dealt with when:

• it had been repaid,
• it had been set off under ICTA88/S239 (1) against the CT liability for the relevant period.

ACT set off under ICTA88/S239 (1) was deemed to comprise ACT of the relevant period in priority to any ACT brought forward, carried back or surrendered to the company. If there were any such amounts it was assumed that the company would not have surrendered any ACT under ICTA88/S240.

• it had been the subject of a carry back claim under ICTA88/S239 (3) and was set off against the CT liability of an earlier period (see CTM20170),
• it had been surrendered by the company under ICTA88/S240,
• it had been set off against the CT liability for the relevant period on a previous application of the section.