Corporation Tax Act 2009 section 24

Application to insurance companies

Section 24 makes special provision for how the separate enterprise principle applies when a non-UK resident insurance company operates through a permanent establishment in the United Kingdom.

• A UK permanent establishment of a non-UK resident insurance company is treated as holding assets of the same quantity and description as a distinct and separate enterprise would hold
• The assets attributed to the permanent establishment may include a proportion of assets held by the wider company
• HMRC may make regulations providing further rules on how the separate enterprise principle applies to insurance companies, including how capital is attributed to the UK permanent establishment
• The asset attribution principles for insurance companies do not prevent similar principles being applied to non-UK resident companies that are not insurance companies