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Contents

Official guidance
General Insurance Manual

GIM5000 · Taxation of the investment return

  • GIM5010 · General overview
  • GIM5020 · The general rule: investment income treated as trading receipt
  • GIM5030 · Exceptions to the general rule: investment income not always taxed as trade profits
  • GIM5040 · UK dividends and other distributions: history and basic rule
  • GIM5050 · UK dividends and other distributions exemption: dividend stripping: distributions made before 1 April 2008
  • GIM5055 · UK dividends and other distributions exemption: dividend stripping: distributions made on or after 1 April 2008: preference share lending
  • GIM5060 · Interest and foreign dividends
  • GIM5070 · Interest and foreign dividends: income received under deduction of tax
  • GIM5080 · Use of trading losses against investment income
  • GIM5090 · Corporate and government debt: accounting periods ending after 31 March 1996: introduction
  • GIM5100 · Corporate and government debt: accounting periods ending after 31 March 1996: rules for insurance companies
  • GIM5110 · Corporate and government debt: exchange differences: accounting periods ending after 31 March 1996 and beginning before 1 October 2002
  • GIM5120 · Corporate and government debt: exchange differences: accounting periods ending after 31 March 1996 and beginning on or after 1 October 2002
  • GIM5130 · Financial instruments: accounting periods beginning before 1 October 2002
  • GIM5140 · Derivative contracts: accounting periods beginning on or after 1 October 2002
  • GIM5150 · Investment gains: accounting periods beginning before 1 January 2002: gains and losses on equities and other non-debt assets
  • GIM5160 · Investment gains: accounting periods beginning before 1 January 2002: portfolio assets and trading stock
  • GIM5170 · The investment return: investment gains: accounting periods beginning before 1 January 2002: portfolio assets and trading stock: periods ending before 1 April 1996
  • GIM5180 · Investment gains: accounting periods beginning before 1 January 2002: the realisation basis
  • GIM5190 · Investment gains: accounting periods beginning on or after 1 January 2002: transition from realisation basis: change of accounting basis
  • GIM5200 · Investment gains: accounting periods beginning on or after 1 January 2002: transition from realisation basis: transitional measures
  • GIM5210 · Investment gains: accounting periods beginning on or after 1 January 2002: transition from realisation basis: transfers of business
  • GIM5220 · Investment gains: accounting periods beginning on or after 1 January 2002: transition from realisation basis: identification of part realisations
  • GIM5230 · Investment gains: structural assets
  • GIM5240 · Investment gains: paper for paper exchange of assets
  • GIM5250 · Investment gains: paper for paper exchange of assets: section 473 ICTA 1988
  • GIM5260 · Investment gains: portfolio assets: anti-avoidance provisions
  • GIM5270 · Investment gains: portfolio assets: exchange differences
  • GIM5280 · Investment gains: land and property
  1. Taxation of the investment return
  2. Taxation of the investment return: use of trading losses against investment income

GIM5080 | Taxation of the investment return: use of trading losses against investment income

From HM Revenue & Customs · General Insurance Manual

Investment income is an integral part of the trading profit (GIM5010). ICTA88/S393 (8) applies to this type of investment income, namely income which would fall to be treated as part of the trade profits but for the exclusivity of the Schedules (see GIM5030).

Such investment income is treated as trading income against which trading losses incurred in an earlier period may be offset under ICTA88/S393.

As ICTA88/S393 (8) applies only to income which has been charged to tax otherwise than as trade profits, its only practical application is likely to be to Schedule A income and to foreign dividends due before 1 April 2001.

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