Commentary

D4.1005 Overseas life assurance business: Credit relief restriction

Corporate tax
Corporate tax | Commentary

D4.1005 Overseas life assurance business: Credit relief restriction

Corporate tax | Commentary

D4.1005 Overseas life assurance business: Credit relief restriction

For accounting periods beginning on or after 1 January 2007 and before 1 January 2013, the trading profits of overseas life assurance business are taxed as part of the composite gross roll up category. (Prior to this the profits were taxed under Schedule D Case VI). For accounting periods beginning on or after 1 January 2013 they are taxed as part of the company's long-term business, see D7.404.

Any foreign tax charged by any territory by reference to trading profit arising in that territory is allowed as a credit against UK tax charged under CTA 2009, s 35 (trading profits) or, for accounting periods beginning before 1 January 2013, ICTA 1988, s 436A (gross roll up profits).

However such credit relief is restricted where foreign tax is charged wholly or partly on some other basis, for example by reference to investment income. In such cases, the amount of such foreign tax is restricted by the

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