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HMRC internal manual

General Insurance Manual

From
HM Revenue & Customs
Updated
, see all updates

Double taxation relief

:
This section describes the treatment of foreign tax suffered by companies carrying on general insurance business.

  1. GIM12010
    Background: types of foreign tax suffered
  2. GIM12020
    Background: Double Taxation Conventions
  3. GIM12030
    Background: residence and similar certificates
  4. GIM12040
    Background: no relief for "company tax deducted"
  5. GIM12050
    Overseas branch profits: calculation
  6. GIM12060
    Overseas branch profits: foreign taxes on UK insurers where there is no "permanent establishment": background
  7. GIM12070
    Overseas branch profits: foreign taxes on UK insurers where there is no "permanent establishment": premium taxes
  8. GIM12080
    Overseas branch profits: foreign taxes on UK insurers where there is no "permanent establishment": admissibility for credit
  9. GIM12090
    Overseas branch profits: foreign taxes on UK insurers where there is no "permanent establishment": "treaty carve out"
  10. GIM12100
    Overseas branch profits: foreign taxes on UK insurers: deemed "permanent establishment"
  11. GIM12110
    Overseas branch profits: creditability of taxes on branch profits: OECD Article 7
  12. GIM12120
    Underlying tax on dividends referable to an overseas branch: accounting periods beginning before 1 April 2000
  13. GIM12130
    Underlying tax on dividends referable to an overseas branch: accounting periods beginning before 1 April 2000: restriction of credit under section 802 ICTA 1988
  14. GIM12140
    Underlying tax on dividends referable to an overseas branch: accounting periods beginning before 1 April 2000: restriction of credit under section 802 ICTA 1988: example
  15. GIM12150
    Underlying tax on dividends referable to an overseas branch: accounting periods beginning before 1 April 2000: section 802 ICTA and Extra-Statutory Concession C1(b)
  16. GIM12160
    Underlying tax on dividends referable to an overseas branch: accounting periods beginning before 1 April 2000: section 802 ICTA & ESC C1(b): information
  17. GIM12170
    Foreign tax on other income: accounting periods beginning before 1 April 2000
  18. GIM12180
    General rules for accounting periods beginning on or after 1 April 2000
  19. GIM12190
    General rules for accounting periods beginning on or after 1 April 2000: income and gains not referable to insurance business
  20. GIM12200
    Foreign tax on investment income: accounting periods beginning on or after 1 April 2000: section 804C ICTA 1988
  21. GIM12210
    Foreign tax on investment income: accounting periods beginning on or after 1 April 2000: section 804C ICTA 1988: limitation of relevant income
  22. GIM12220
    Foreign tax on investment income: accounting periods beginning on or after 1 April 2000: section 804C ICTA 1988: the first limitation - for expenses
  23. GIM12230
    Foreign tax on investment income: accounting periods beginning on or after 1 April 2000: section 804C ICTA 1988: the first limitation: example
  24. GIM12240
    Foreign tax on investment income: accounting periods beginning on or after 1 April 2000: section 804C ICTA 1988: meaning of “total relevant expenses” and “total income”
  25. GIM12250
    Foreign tax on investment income: accounting periods beginning on or after 1 April 2000: section 804C ICTA 1988: the first limitation: shortcut
  26. GIM12260
    Foreign tax on investment income: accounting periods beginning on or after 1 April 2000: section 804C ICTA 1988: the second limitation: purpose of section 804C(4)
  27. GIM12270
    Foreign tax on investment income: accounting periods beginning on or after 1 April 2000: section 804C ICTA 1988: the second limitation: section 804C(4) calculation
  28. GIM12280
    Foreign tax on investment income: accounting periods beginning on or after 1 April 2000:: section 804C ICTA 1988: the second limitation: example
  29. GIM12290
    Foreign tax on investment income accounting periods beginning on or after 1 April 2000: section 804C ICTA 1988: limitations applied to a non-insurance subsidiary
  30. GIM12300
    Foreign tax on investment income: accounting periods beginning on or after 1 April 2000: section 804C ICTA 1988: interaction of credit relief and relief as expense