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Legislation
Taxation (International and Other Provisions) Act 2010

Chapter 6 The CFC charge gateway: trading finance profits

  • Section 371FA The basic rule
  • Section 371FB Qualifying loan relationships
  • Section 371FC Loans from foreign permanent establishments of UK resident companies
  • Section 371FD Exclusion: banking business
  • Section 371FE Exclusion: insurance business
  1. Chapter 6 · The CFC charge gateway: trading finance profits
  2. Exclusion: insurance business

Section 371FE | Exclusion: insurance business

From legislation.gov.uk

(1)The HMRC Commissioners may by regulations provide that, if specified conditions are met, step 3 in section 371FA(1) is not to apply in relation to the CFC's trading finance profits so far as they arise from insurance business, or insurance business of a specified description, carried on by the CFC.

(2)In subsection (1) “insurance business” does not include insurance business so far as consisting of the effecting or carrying out of contracts of insurance covered by section 371GA(2) (UK insurance contracts), including the investment of premiums received from such contracts.

(3)Regulations under subsection (1) may (in particular) make provision by reference to—

(a)the territory in which a CFC is resident or any territory in which its insurance business is regulated or carried on, or

(b)the regulatory requirements imposed from time to time in any territory in relation to insurance business.

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