CTM18720 - Shadow ACT: unrelieved surplus: set-off

The amount of unrelieved surplus ACT to be set against the company바카라 사이트™s liability to CT for any accounting period beginning on or after 6 April 1999 is the lesser of:

  • the amount of unrelieved surplus ACT to the extent that it cannot be set against the liabilities for an earlier accounting period, including any controlled foreign companies liabilities, and
  • the amount of the company바카라 사이트™s capacity calculated in accordance with Regulation 11, less the amount of any shadow ACT allocated to that period in accordance with Regulations 12 and 13.

Where section ICTA88/S116 (2) applies (arrangements for transferring relief),unrelieved surplus ACT cannot be set against a company바카라 사이트™s liability to CT on its share of partnership profits.