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HMRC internal manual

International Manual

From
HM Revenue & Customs
Updated
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Controlled Foreign Companies: United Kingdom companies carrying on life assurance business: Special rules for United Kingdom companies carrying on life assurance business

There are special rules for ascertaining the ‘appropriate rate’ and ‘creditable tax’ on the apportionment of the chargeable profits and creditable tax of a controlled foreign company where the relevant interest is held by a United Kingdom resident company carrying on the business of life assurance. These rules reflect the tax treatment of UK life assurance business.