Commentary

D7.522 General principles

Corporate tax
Corporate tax | Commentary

D7.522 General principles

Corporate tax | Commentary

Apportionment

D7.522 General principles

The rules in this division apply for accounting periods beginning before 1 January 2013. For accounting periods beginning on or after 1 January 2013 see Division D7.4.

Because life insurance business must be separated into categories for tax purposes, a method must be found for allocating investment income and gains among the different categories to enable the appropriate tax computations to be made. HMRC do not accept that investments are specifically held for or hypothecated to different funds, unless the constitution of the company so provides and investments are held specifically for policy holders of a specified fund. In the normal case

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