Section 171 | Taxation of profits and allowance of losses.

(1)Income tax for any year of assessment on the profits arising from a member’s underwriting business shall be computed on the profits of that year of assessment.

(2)As respects the profits arising to a member from his underwriting business for any year of assessment—

(a)the aggregate of those profits shall be chargeable to tax under Chapter 2 of Part 2 of the Income Tax (Trading and Other Income) Act 2005 as the profits of a trade carried on in the United Kingdom; and

(b)accordingly, no part of those profits shall be treated as relevant foreign income, or be charged to tax under any other Part of that Act or any Part of the Income Tax (Earnings and Pensions) Act 2003;

but nothing in this subsection shall affect the manner in which the amount of any profits arising from assets forming part of an ancillary trust fund is to be computed.

(2A)Repealed

(2B)Repealed

(3)Repealed

(4)Subsection (2) above does not apply in relation to any profits arising before 6th April 1993 from assets forming part of an ancillary trust fund.