Advance Corporation Tax Reform: Call for Evidence

Advance Corporation Tax (ACT) was abolished in 1999. Transitional rules still allow companies with remaining ACT balances to use them subject to limitations known as the ‘shadow ACT’ rules. The government is repealing these restrictive ‘shadow ACT’ rules from 1 April 2026, and is now exploring phasing out the remaining ACT regime entirely. This Call for Evidence seeks input on the likely timescales to use remaining ACT balances and the potential impact on taxpayers of removing the ACT rules. The government will not decide whether this repeal will go ahead or the timing of such repeal before considering the responses to this call for evidence.