GIM10240 | Non-resident insurers: other taxation issues: taxation of non- residents generally

The taxation of UK permanent establishments of foreign general insurers resembles in most respects the taxation of other non-resident companies trading in the UK. For ways in which the corporation tax system applies differently to non-resident companies trading in the UK see, in particular:

• CTM34230 to CTM34270 - non-resident companies generally

• CTM56305+ and CFM6300+ - loan relationships: imported losses

• CTM56710, CFM6214 and CFM13611 - loan relationships and derivative contracts: unallowable purposes where debits not connected with UK activities

• CFM10521 - accounting in currency other than sterling

• CG42000 onwards - chargeable gains.

This general alignment of treatment between general insurers and non-resident companies as a whole means that the treatment of non-resident general insurers and that of overseas life insurance companies can sometimes be different. The Life Assurance Manual (LAM) gives details of the treatment of overseas life assurance companies.