Commentary

D7.427 Dividends and other distributions

Corporate tax
Corporate tax | Commentary

D7.427 Dividends and other distributions

Corporate tax | Commentary

D7.427 Dividends and other distributions

Normally dividends and other distributions received by a company are exempt from tax by virtue of CTA 2009, Pt 9A and this is also true for insurance companies when calculating their I-E profit (see D7.436). In calculating their trade profit however, whether from BLAGAB or non-BLAGAB business, life insurers are required to include distributions as taxable receipts1.

This rule applies regardless of whether the distributions would be exempt under CTA 2009, Pt 9A but does not apply to capital distributions2.

In broad terms this represents the fact that a dividend received by a life insurer on a

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