Corporation Tax Act 2010 section 269ZFB

Modifications for certain insurance companies

Section 269ZFB modifies the way the corporate loss restriction rules calculate "relevant profits" for insurance companies that carry on basic life assurance and general annuity business (BLAGAB).

• This section applies only to insurance companies that carry on BLAGAB during the accounting period in question.
• When calculating relevant profits for the loss restriction, BLAGAB income is not automatically excluded — it is only excluded if it relates to company distributions that are taxed under the exempt distributions rules because of a specific election.
• Only the policyholders' share of any BLAGAB I-E profit (investment income less expenses profit) is left out of the calculation; the shareholders' share remains within the relevant profits figure.
• No deductions of non-BLAGAB allowable losses may be set against the shareholders' share of BLAGAB chargeable gains when arriving at relevant profits.