Skip to content
Solved

GIM12000 | Double taxation relief

From HM Revenue & Customs · General Insurance Manual

This section describes the treatment of foreign tax suffered by companies carrying on general insurance business.

Contents30 entries

  1. GIM12010Double Taxation Relief: background: types of foreign tax suffered
  2. GIM12020Double Taxation Relief: background: Double Taxation Conventions
  3. GIM12030Double Taxation Relief: background: residence and similar certificates
  4. GIM12040Double Taxation Relief: background: no relief for "company tax deducted"
  5. GIM12050Double Taxation Relief: overseas branch profits: calculation
  6. GIM12060Double Taxation Relief: overseas branch profits: foreign taxes on UK insurers where there is no "permanent establishment": background
  7. GIM12070Double taxation relief: overseas branch profits: foreign taxes on UK insurers where there is no "permanent establishment": premium taxes
  8. GIM12080Double taxation relief: overseas branch profits: foreign taxes on UK insurers where there is no "permanent establishment": admissibility for credit
  9. GIM12090Double taxation relief: overseas branch profits: foreign taxes on UK insurers where there is no "permanent establishment": "treaty carve out"
  10. GIM12100Double taxation relief: overseas branch profits: foreign taxes on UK insurers: deemed "permanent establishment"
  11. GIM12110Double taxation relief: overseas branch profits: creditability of taxes on branch profits: OECD Article 7
  12. GIM12120Double taxation relief: underlying tax on dividends referable to an overseas branch: accounting periods beginning before 1 April 2000
  13. GIM12130Double taxation relief: underlying tax on dividends referable to an overseas branch: accounting periods beginning before 1 April 2000: restriction of credit under section 802 ICTA 1988
  14. GIM12140Double taxation relief: underlying tax on dividends referable to an overseas branch: accounting periods beginning before 1 April 2000: restriction of credit under section 802 ICTA 1988: example
  15. GIM12150Double taxation relief: underlying tax on dividends referable to an overseas branch: accounting periods beginning before 1 April 2000: section 802 ICTA and Extra-Statutory Concession C1(b)
  16. GIM12160Double taxation relief: underlying tax on dividends referable to an overseas branch: accounting periods beginning before 1 April 2000: section 802 ICTA & ESC C1(b): information
  17. GIM12170Double taxation relief: foreign tax on other income: accounting periods beginning before 1 April 2000
  18. GIM12180Double taxation relief: general rules for accounting periods beginning on or after 1 April 2000
  19. GIM12190Double taxation relief: general rules for accounting periods beginning on or after 1 April 2000: income and gains not referable to insurance business
  20. GIM12200Double taxation relief: foreign tax on investment income: accounting periods beginning on or after 1 April 2000: section 804C ICTA 1988
  21. GIM12210Double taxation relief: foreign tax on investment income: accounting periods beginning on or after 1 April 2000 section 804C ICTA 1988: limitation of relevant income
  22. GIM12220Double taxation relief: foreign tax on investment income: accounting periods beginning on or after 1 April 2000: section 804C ICTA 1988: the first limitation - for expenses
  23. GIM12230Double taxation relief: foreign tax on investment income: accounting periods beginning on or after 1 April 2000: section 804C ICTA 1988: the first limitation: example
  24. GIM12240Double taxation relief: foreign tax on investment income: accounting periods beginning on or after 1 April 2000: section 804C ICTA 1988: meaning of "total relevant expenses" and "total income"
  25. GIM12250Double taxation relief: foreign tax on investment income: accounting periods beginning on or after 1 April 2000: section 804C ICTA 1988: the first limitation: shortcut
  26. GIM12260Double taxation relief: foreign tax on investment income: accounting periods beginning on or after 1 April 2000: section 804C ICTA 1988: the second limitation: purpose of section 804C(4)
  27. GIM12270Double taxation relief: foreign tax on investment income: accounting periods beginning on or after 1 April 2000: section 804C ICTA 1988: the second limitation: section 804C(4) calculation
  28. GIM12280Double taxation relief: foreign tax on investment income: accounting periods beginning on or after 1 April 2000: section 804C ICTA 1988: the second limitation: example
  29. GIM12290Double taxation relief: foreign tax on investment income: accounting periods beginning on or after 1 April 2000: section 804C ICTA 1988: limitations applied to a non-insurance subsidiary
  30. GIM12300Double taxation relief: foreign tax on investment income: accounting periods beginning on or after 1 April 2000: section 804C ICTA 1988: interaction of credit relief and relief as expense