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HMRC internal manual

International Manual

Distribution exemption: Interpretation: general insurance companies and Lloyds

Rules for general insurance companies and Lloyd’s

CTA09/S130 now extends the exemption for UK company distributions received to include all dividends and other distributions exempt under CTA09/Part 9A, including most foreign distributions.

The special Lloyd’s corporate member tax legislation at FA94/S219 is now amended to exempt both foreign and UK distributions received by corporate members. Before this amendment, Lloyd’s corporate members, uniquely among general insurers, were charged to tax on UK dividends received, as well as on foreign dividends.