Corporation Tax Act 2009 section 1161

Relief in respect of I minus E basis: expenses payable

Section 1161 sets out the conditions that life assurance companies taxed on the I minus E basis must satisfy to claim relief for qualifying land remediation expenditure, and explains the form that relief takes.

• The company must hold a major interest in UK land that is a management asset used for, or intended for use in, managing its basic life assurance and general annuity business.
• Contaminated land must have been contaminated when the company acquired it; derelict land must have been derelict continuously since at least 1 April 1998 or the date the company (or a connected person) first acquired a major interest in it, whichever is earlier.
• The company must incur qualifying land remediation expenditure on the land during the accounting period in question.
• Where all three conditions are met, the qualifying expenditure may be treated as expenses payable and deducted at Step 1 in section 76 of FA 2012, enhancing the management expenses the company can bring into account.