Corporation Tax Act 2010 section 188BG

Restrictions for certain insurance companies

Section 188BG restricts certain types of insurance companies from surrendering specific carried-forward losses and expenses to other group companies.

• General insurance companies cannot surrender carried-forward non-trading losses on intangible assets, management expenses, or property losses during an excluded accounting period
• Solvency 2 insurance companies face the same restrictions but only to the extent that the losses or expenses qualify as a "shock loss"
• Solvency 2 insurance companies are additionally prevented from surrendering carried-forward BLAGAB (basic life assurance and general annuity business) trade losses where these are shock losses
• These restrictions apply to group relief for carried-forward amounts and prevent the transfer of these specific items to other group members