Double taxation relief (DTR) for companies is covered generally in Division D4.8. There are, however, some specific provisions for companies which carry out life assurance business which restrict the DTR credit available.
The foreign permanent establishment exemption can apply to life insurance companies (see D4.801A). However, when calculating the relevant profits (or losses) amount the profits (or losses) arising from basic life assurance and general annuity business (BLAGAB) must be excluded (and so are not exempt)1.
When calculating DTR for companies which carry out life assurance business, foreign tax is allocated between categories of business, and the limit for credit for each category is considered separately2. There are also specific rules relating to overseas life assurance business (see below).
In summary, the legislation establishes how foreign tax, in relation to an item of relevant income is allocated between categories of business, and it provides that the amount of credit against corporation tax on the relevant
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