28 Deemed receipts under s 26(4): double taxation relief

28  Deemed receipts under s 26(4): double taxation relief

(1)     This section applies if—

(a)     a receipt is treated as arising to an insurance company's business in an accounting period as a result of section 26(4),

(b)     the company carries on business through a permanent establishment outside the United Kingdom by reference to which double taxation relief is afforded in respect of any income or gains, and

(c)     the permanent establishment is one in relation to which regulation 10(2) of the Insurance Companies (Reserves) (Tax) Regulations 1996 previously applied.

(2)     For the purpose of calculating

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