20(1)  In any case where–

(a)an amount of chargeable profits (“Chapter IV profits”) of a controlled foreign company is apportioned to a company resident in the United Kingdom under the provisions of Chapter IV of Part XVII of the Taxes Act, and

(b)the company to whom the amount is apportioned has an amount of surplus shadow ACT, calculated in accordance with regulation 12 and (where applicable) regulation 13, available to be set against the company’s liability to corporation tax for the appropriate accounting period (including, by virtue of regulation 3(3), its liability to tax under section 747(4) for that period),

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