96 Companies with overseas branches: restriction of credit

Insurance companies

96  Companies with overseas branches: restriction of credit

(1)     Subsection (4) applies if credit for foreign tax—

(a)     which is payable in respect of insurance business carried on by a company through a permanent establishment in the non-UK territory, and

(b)     which is calculated otherwise than wholly by reference to profits arising in the non-UK territory,

is to be allowed (in accordance with this Part) against corporation tax charged under section 35 of CTA 2009 . . . in respect of the profits. . . of [non-BLAGAB long-term business] carried on by the company in an accounting period (in this section called “the relevant UK-taxable profits”).

(2)

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