Corporation Tax Act 2009 section 634

Insurance companies

Section 634 provides that certain activities carried on by insurance companies are not treated as constituting a trade for the purposes of the intangible fixed assets regime.

• Mutual insurance or other mutual business (excluding life assurance) carried on by a company is treated as not being a trade
• This mirrors the treatment applied to mutual trading companies under the preceding section, but applies specifically to insurance companies
• Basic life assurance and general annuity business is dealt with separately under the I minus E (income less expenses) rules in section 88 of Finance Act 2012
• The distinction matters because, if an activity is not treated as a trade, the intangible fixed assets rules in this Part of the Act do not apply to it on a trading basis