11(1)  Where a company resident in the United Kingdom makes a relevant distribution, other than a relevant distribution to which paragraph (2) applies, shadow ACT shall, for the purposes of determining the amount of unrelieved surplus ACT that may be set against a company’s liability to corporation tax for an accounting period in accordance with regulation 14, be treated as having been paid by the company in accordance with the provisions of this regulation.

11(2)  This paragraph applies to a relevant distribution–

(a)which is a manufactured dividend to which paragraph 2(2) of Schedule 23A applies, or

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