Taxation (International and Other Provisions) Act 2010 section 259ZMD

The unused part of the DII shortfall

Section 259ZMD explains how to calculate the remaining unused portion of a company's dual inclusion income (DII) shortfall for a given period, taking into account any amounts already claimed through previous allocation claims.

• The unused part of the DII shortfall equals the total shortfall minus amounts already matched through prior allocation claims that have not been withdrawn.
• Prior allocation claims are earlier claims made by the same company for the same shortfall period that remain in force (i.e. have not been withdrawn).
• Each prior claim's matched amount is the amount that was treated as dual inclusion income of the company as a result of that earlier claim.
• Where multiple allocation claims are made simultaneously, the company may elect the order in which they are treated as having been made; failing such an election, HMRC may direct the order.

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