Corporation Tax Act 2010 section 67B

Exclusion in the case of property businesses of insurance companies

Section 67B excludes insurance company property business losses from the general loss relief rules in Chapter 4, directing them instead to the special Insurance minus Expenses (I minus E) regime under the Finance Act 2012.

• The general loss relief rules in Chapter 4 of CTA 2010 do not apply to losses made by an insurance company in its separate UK or overseas property businesses that fall within the I minus E framework.
• These separate property businesses are those identified under section 86(4) of the Finance Act 2012, which requires insurance companies to maintain distinct property businesses for tax purposes.
• Where a property business loss is attributable to the company's basic life assurance and general annuity business (BLAGAB), specific rules in section 87(3) and (4) of the Finance Act 2012 apply instead.
• The attribution of losses to BLAGAB is determined in accordance with Chapter 4 of Part 2 of the Finance Act 2012.