Commentary

D7.539 Exclusions

Corporate tax
Corporate tax | Commentary

D7.539 Exclusions

Corporate tax | Commentary

D7.539 Exclusions

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 following types of reinsurance arrangements are excluded from business for which a notional investment return has to be calculated.

Intra-group transactions (using a 90% test for group membership) where both the cedant and reinsurer are either UK resident or non-resident but within the charge to corporation tax in respect of the business concerned and the reinsurer is not charged under the life assurance trade profit provisions1.

  1.  

    (a)     Business in respect of which the reinsurer fills all the following conditions:

    1.  

      (1)     the reinsurer is chargeable to tax in its territory of residence or domicile in respect of amounts arising from the reinsurance;

    2.  

      (2)     it has its head office in an EEA State

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