The FID scheme was abolished with effect from 6 April 1999. FIDs were introduced by the Finance Act 1994 to provide some relief for UK resident companies with substantial earnings overseas. Since such earnings would frequently bear little further corporation tax because of credits for foreign tax suffered on the income, such companies frequently found that they could not recover advance corporation tax (ACT) because they had an insufficient liability to mainstream corporation tax. Under the FID legislation, companies could elect by notice to HM Revenue & Customs on or before payment of the dividend, that the dividend should be treated as a FID. The company paid ACT in the normal way but, broadly, was able to reclaim the ACT if it was surplus because of foreign tax on profits. FIDs did not carry a repayable tax credit for shareholders. The compatability of FIDs with EU law has been the subject of litigation in the UK courts and the ECJ, see Practice note, ECJ direct tax cases: where are they now?: FID Group Litigation and Legal update, ECJ agrees article 63 confers rights directly on shareholders receiving FIDs.