Commentary

D7.473 BLAGAB trade loss—Group relief

Corporate tax
Corporate tax | Commentary

D7.473 BLAGAB trade loss—Group relief

Corporate tax | Commentary

D7.473 BLAGAB trade loss—Group relief

The rules in this division apply for accounting periods beginning on or after 1 January 2013. For accounting periods beginning before 1 January 2013 see Division D7.5.

As with trade losses arising to non-insurance companies, a BLAGAB trade loss may be surrendered as group relief despite the fact that a BLAGAB trade profit would not be charged to tax under CTA 2009, s 35 because of the application of the charge on the I-E basis1.

In order to reflect the particular nature of life insurance business and the policyholders' interest in it, if a life insurance company

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