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HMRC internal manual

General Insurance Manual

Non-resident insurers: other taxation issues: taxation of non- residents generally

The taxation of UK permanent establishments of foreign general insurers resembles in most respects the taxation of other non-resident companies trading in the UK. For ways in which the corporation tax system applies differently to non-resident companies trading in the UK see, in particular:

  • CTM34230 to CTM34270 - non-resident companies generally
  • CTM56305+ and CFM6300+ - loan relationships: imported losses
  • CTM56710, CFM6214 and CFM13611 - loan relationships and derivative contracts: unallowable purposes where debits not connected with UK activities
  • CFM10521 - accounting in currency other than sterling
  • CG42000 onwards - chargeable gains.This general alignment of treatment between general insurers and non-resident companies as a whole means that the treatment of non-resident general insurers and that of overseas life insurance companies can sometimes be different. The Life Assurance Manual (LAM) gives details of the treatment of overseas life assurance companies.