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HMRC internal manual

General Insurance Manual

HM Revenue & Customs
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Double Taxation Relief: overseas branch profits: foreign taxes on UK insurers where there is no "permanent establishment": background


A number of overseas countries and territories levy taxes on the profits derived by non- resident insurers from insurance operations in those territories where the extent of those operations falls short of anything that the UK would regard as constituting a branch or permanent establishment.

And, whether or not a branch exists, tax may be levied on a figure of profit that is computed on some purely conventional basis.

GIM12070 to GIM12090 deal with the extent to which credit relief is available against UK corporation tax for the foreign tax in question. This varies, depending upon whether relief is given unilaterally or by treaty, and on the terms of any treaty that may be relevant. “Income tax” in this context means any tax that is levied on corporate profits of an income nature, by whatever name it may be called.