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HMRC internal manual

International Manual

Controlled Foreign Companies: United Kingdom companies carrying on life assurance business: Appropriate rate: trading profits

Where the profits of a controlled foreign company fall to be apportioned on a United Kingdom resident company

  • which carries on a life assurance business in the accounting period in which the accounting period of the controlled foreign company ends, and 
  • the property or rights constitute to any extent assets of the United Kingdom company’s long term business fund, and 
  • the United Kingdom company is charged to tax in respect of its profits from life assurance, then

the appropriate rate for the purposes of ICTA88/S747(4)(a) and ICTA88/SCH24/PARA1 is nil to the extent that the interest giving rise to the apportioned profit represents assets of the ‘long-term business fund’ ‘Long term business fund’ has the meaning in ICTA88/S431(2).