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Shadow/Surplus ACT

Co has y/e 31.8.05 with PCTCT of £132,531. Pays divis in year of £160,075. Co also has unrelieved surplus ACT from pre-99 dividends of £5,884.

I know that for purposes of calculating whether surplus ACT of £5,884 can be offset against 31.8.05, one has to look at the "shadow ACT" on the divis paid in the year. However, how is the shadow ACT calculated? Is it 20/80 of £160,075 (divis actually paid), or 20/80 of £132,531 (because divis for NCD purposes are £132,531, with £27,544 being excess NCDs c/f)?

Timothy Burden

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Shadow ACT
25% of the gross dividends paid plus the shadow ACT, assuming no FII . See HMRC manuals: CT 1855.

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Shadow ACT
Sorry if my post was confusing. I intended to confirm that shadow ACT is calculated as 25% of the distributions actually made in an AP, so this would be on the £160075, if there is no FII to set against them.

There will therefore be surplus shadow ACT to carry back.

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????
Am I being a bit thick, here? How can I add the Shadow ACT when I dont know how to calculate it? (which is my question).

Are you saying that NCD rules do not come into this at all? CT1855 does not address this.

And no FII.

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Thanks.....
.....for clarification. Co made losses in all yrs post 99 to pre 05 so no scope for carry back. Therefore all Shadow ACT to be c/f.

Seems strange that in next y/e 31.8.06, we have one divi figure for which to take SACT into account and another for NCD purposes (as £27,544 b/f from 31.8.05)!

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