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HMRC internal manual

General Insurance Manual

Double taxation relief: underlying tax on dividends referable to an overseas branch: accounting periods beginning before 1 April 2000: section 802 ICTA & ESC C1(b): information


Rates of foreign tax required by insurance companies in respect of dividends which qualify for relief under ICTA88/S802 are computed by the Underlying Tax Group, FitzRoy House, Nottingham in accordance with special arrangements agreed with the Association of British Insurers.

Each insurance company must submit to the LBS to which it makes its return a list of the foreign companies for which rates of foreign tax are required, for each accounting period (not later than nine months after the end of that year), showing

  • the names of the foreign companies (in alphabetical order) for which rates are required, for each foreign country concerned;
  • the amount of the dividend received from each foreign company;
  • a note (where possible) of those foreign companies for which a rate is required otherwise than for the purpose of section 802. This will normally be for those cases where relief for underlying tax is available under section 801 (including as extended by ESC/C1 (b)), but see also INTM164410.

The LBS send this to the Underlying Tax Group in Nottingham, which will notify the LBS of the rates in due course.

Details of the arrangements are circulated by the ABI to all companies which are members of the Association. Companies which are not members of the ABI should be asked to adopt similar arrangements.

Where the lists contain names of foreign companies for which rates are required otherwise than for the purposes of section 802, the instructions in INTM164410 and INTM164420 should be observed.