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HMRC internal manual

International Manual

Controlled Foreign Companies: United Kingdom companies carrying on life assurance business: Apportioned profit referable to particular business

The part of the apportioned profit which is referable to:

pension business,

life reinsurance business,

overseas life assurance business, or

basic life assurance and general annuity business

which is carried on by the United Kingdom company is the part that would have been so referable under ICTA88/S432A if the apportioned profit had been a dividend paid to the United Kingdom company at the end of the accounting period in which the apportionment falls to be made.