Commentary

D7.531 Income from land

Corporate tax
Corporate tax | Commentary

D7.531 Income from land

Corporate tax | Commentary

Taxation of BLAGAB income

D7.531 Income from land

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.

The normal rules for taxing income from land under CTA 2009, Pt 4 Ch 3 as a single business1 (see Part B9) are modified for insurance companies2. This reflects the fact that the single business concept does not sit well with the direct attribution of income in the context of linked business or ring-fenced foreign business assets (and for accounting periods beginning before 1 January 2007 assets assigned to the overseas life assurance fund).

To deal with the anomalous results that might otherwise occur, the exploitation of land held as an asset of an insurance company's long-term insurance fund is treated as a separate business from the exploitation of any land held outside that fund3. Land held as an asset linked to:

  1.  

    (a)     BLAGAB;

  2.  

    (b)     gross roll up business; and

  3.  

    (c)     PHI business.

For accounting periods beginning before 1 January 2007 this list was expanded to reflect the various categories of business previously recognised for tax purposes:

  1.  

    (a)     pension business;

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to TolleyLibrary or register for a free trial