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Contents

Official guidance
General Insurance Manual

GIM4000 · Taxation of general insurance

  • GIM4010 · Introduction
  • GIM4020 · Historical background
  • GIM4030 · General rules
  • GIM4040 · UK GAAP and International Accounting Standards
  • GIM4050 · Overview of the accounts
  • GIM4060 · Annual accounting: accounting for premium income
  • GIM4070 · Annual accounting: UPP
  • GIM4080 · Annual accounting: acquisition costs and administrative expenses
  • GIM4090 · Annual accounting: capital allowances
  • GIM4100 · Annual accounting: intangible assets
  • GIM4110 · Annual accounting: currency accounting: APs beginning before 1 January 2005: general rules
  • GIM4120 · Annual accounting: currency accounting: general rules: APs beginning before 1 January 2005: sections 93 and 93A FA 1993
  • GIM4130 · Annual accounting: currency accounting: general rules: APs beginning on or after 1 January 2005
  • GIM4140 · Funded accounting: general
  • GIM4150 · Funded accounting: an example
  • GIM4160 · Funded accounting: CTSA implications
  • GIM4170 · Funded accounting: CTSA enquiry windows
  • GIM4180 · Funded accounting: other tax issues
  • GIM4190 · Commencement and cessation
  • GIM4200 · Insolvency
  • GIM4210 · Business in run-off
  • GIM4220 · Transfers of business: general
  • GIM4230 · Transfers of business: tax treatment
  • GIM4240 · Transfers of business: transfer of trading losses
  • GIM4250 · Composite insurance companies
  • GIM4260 · Insurance premium tax (IPT)
  • GIM4270 · VAT
  • GIM4280 · Interest and penalties
  1. Taxation of general insurance
  2. Taxation of general insurance: composite insurance companies

GIM4250 | Taxation of general insurance: composite insurance companies

From HM Revenue & Customs · General Insurance Manual

A composite insurance company carries on both long-term and general business.

Life assurance and post-1937 capital redemption business is treated as a trade separate from any other insurance business by reason of ICTA88/S431H (formerly by reason of ICTA88/S432 and ICTA88/S458A). This over-rides the principle that insurance is a single trade (see for instance Last v London Assurance Corporation 2TC100).

Companies may prepare separate computations for, say, permanent health insurance, and general insurance business. But the results of these separate computations must then be combined to determine the overall figure of profit or loss.

Section 6 Insurance Companies Act 1982 prohibited the authorisation of new composite insurers, unless they were reinsurers or ‘healthcare composites’ conducting general insurance business falling within Classes 1 and 2 (Accident and Sickness Insurance) together with any class of long term business. This is now reflected in the rules in the FSA Handbook (see GIM3070 onwards). Where a company does have the two categories of business, the Handbook requires composites to follow the separate solvency requirements for each.

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