Corporation Tax Act 2009 section 901

Effect of application of the I - E basis: non-trading amounts

Section 901 ensures that credits and debits relating to a life assurance company's basic life assurance and general annuity business are taxed consistently with the I minus E basis, rather than being treated as trading or property business amounts.

  • The I minus E rules govern how a life assurance company's basic life assurance and general annuity business is taxed for corporation tax purposes.
  • When applying the intangible fixed assets rules in this Part, they must be read alongside section 88 of Finance Act 2012.
  • Section 88 of Finance Act 2012 provides that the activities carried on in the course of basic life assurance and general annuity business do not constitute the whole or any part of a trade or a property business.
  • The practical effect is that intangible fixed asset credits and debits referable to this business are treated as non-trading amounts, consistent with the I minus E taxation framework.

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