Double taxation relief was given in priority to ACT for
accounting periods beginning on or after 3 June 1986.
The rules in Section 797 (4) and (5) ensured that the limit
imposed by ICTA88/S239 (2) on the maximum ACT set-off was applied
separately to the foreign taxed and non-foreign taxed income or
gains.
For detailed guidance on the interaction of ACT and double
taxation relief see INTM167000 onwards.