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HMRC internal manual

Business Income Manual

Specific deductions: insurance: Export Credits Guarantee scheme

S91 Income Tax (Trading and Other Income) Act 2005, S91 Corporation Tax Act 2009

A trading deduction is allowed for sums paid to the Export Credits Guarantee Department under arrangements for insuring overseas investments pursuant to S2 Export and Investments Guarantee Act 1991, whether or not the amounts would be allowable on normal principles.

Under the Export Credits Guarantee Department’s scheme, insurance is offered against risks of expropriation, war and currency inconvertibility. The scheme applies not only to assets of overseas branches but also to equity and loan capital in overseas companies.