Commentary

D7.586 Foreign business assets

Corporate tax
Corporate tax | Commentary

D7.586 Foreign business assets

Corporate tax | Commentary

D7.586 Foreign business assets

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.

As part of the FA 2007 changes introducing gross roll up business the overseas life assurance fund was abolished and replaced by the concept of foreign business assets (originally foreign currency assets).

The foreign business assets regime identifies those non-linked assets attributable to a company's overseas business. There is no need for the legislation to deal with linked assets because income and gains arising on such assets are already directly referable to the gross roll up business category under ICTA 1988, s 432A(3).

For accounting periods beginning on or after 1 January 2008 foreign business assets are defined as either:

  1.  

    (a)     assets shown in the company's records as primarily attributable to its foreign business; or

  2.  

    (b)     assets attributable to a permanent establishment outside the UK under the laws of the country in which

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