Corporation Tax Act 2009 section 564

Section 563: interpretation

Section 564 defines the key terms used in section 563, specifically the meaning of a "BLAGAB contract" and the conditions that must be met for a contract to be considered subject to a relevant comparable EEA tax charge.

  • A BLAGAB contract is one forming part of an insurance company's basic life assurance and general annuity business, excluding business exempt from corporation tax as friendly society or former friendly society business
  • A contract is subject to a relevant comparable EEA tax charge if it forms part of the business of another company (not the relevant company itself) to which such a charge has applied
  • The EEA tax charge must apply at a rate of at least 20% on the amounts subject to tax, disregarding amounts from investments that benefit from a generally available special relief or exemption
  • The charge must be imposed otherwise than by reference to the company's profits, meaning it is a tax on investment income or gains rather than a profits-based tax

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