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HMRC internal manual

International Manual

Controlled Foreign Companies: United Kingdom companies carrying on life assurance business: Creditable tax: not trading profits

Where creditable tax is apportioned to a United Kingdom company carrying on life assurance business and that company is not charged to tax in respect of its life assurance profits and the apportioned profit is referable to one of the following categories of business:

pension business,

life reinsurance business, or

overseas life assurance business,

the creditable tax shall be treated as extinguished.