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HMRC internal manual

General Insurance Manual

Double taxation relief: general rules for accounting periods beginning on or after 1 April 2000: income and gains not referable to insurance business


Where income or gains are not referable to general insurance business (nor, in the case of a composite, to life assurance business), the full amount of foreign tax suffered, including underlying tax, will normally be creditable. This assumes that sufficient income is left chargeable to corporation tax after the operation of ICTA88/S797 and ICTA88/S797A and the pooling rules for foreign dividends. Where foreign tax on any dividend arising after 31 March 2001 within the charge under Case V of Schedule D exceeds the amount that may be given as credit against corporation tax, either because of ICTA88/S797 or the “mixer cap” in ICTA88/S799 (1A), the excess, subject to the rules in ICTA88/S806B and ICTA88/S806C, may be carried forward or back under ICTA88/S806D by virtue of a claim under ICTA88/S806G. However, it may only be set against corporation tax on the dividends described above, and not against the tax on dividends included in a Case I computation of general insurance business profits.