Section 97 | Companies with more than one category of business: restriction of credit

(1)This section applies if—

(a)an insurance company carries on more than one category of long-term business in an accounting period, and

(b)there arises to the company in that period any income or gain (“the relevant income”) in respect of which credit for foreign tax is to be allowed under the arrangements.

(2)The amount of the credit for foreign tax which, under the arrangements, is allowable against corporation tax in respect of so much of the relevant income as is referable, in accordance with Part 2 of FA 2012, to a particular category of business must not exceed the fraction of the foreign tax which, in accordance with subsection (3), is attributable to that category of business.

(3)The fraction of the foreign tax that is attributable to the category of business in question is the fraction given by—