CTM81265 - Groups: surrender of ACT: payment by subsidiary for surrender
ICTA88/S240 (8)
If a payment is made by a subsidiary to a surrendering company under an agreement between them for the surrender of ACT, and the payment does not exceed the amount surrendered, the payment is not to be:
- taken into account in computing the profits or losses of either company for CT purposes,
and
- regarded as a distribution or a charge on income.