PART 2Insurance companies carrying on long-term business

CHAPTER 2Charge to tax on I - E basis etc

Separate businesses etc

C166Separate businesses for BLAGAB and other long-term business

1

If an insurance company carries on—

a

basic life assurance and general annuity business, and

b

other long-term business,

the general rule is that business within paragraphs (a) and (b) is to be treated for corporation tax purposes as two separate businesses carried on by the company.

2

One of the separate businesses is to consist of the basic life assurance and general annuity business.

3

The other separate business is to be regarded for corporation tax purposes as a single trade consisting of the other long-term business.

4

If an insurance company carries on—

a

life assurance business none of which is basic life assurance and general annuity business, and

b

PHI business,

the company is to be treated for corporation tax purposes as carrying on a single trade consisting of the businesses within paragraphs (a) and (b).

5

For the purposes of this Part “non-BLAGAB long-term business” means—

a

a single trade within subsection (3) or (4), or

b

in a case where an insurance company carries on life assurance business none of which is basic life assurance and general annuity business but does not carry on other long-term business, that life assurance business.

6

If an insurance company carries on short-term insurance business, that business is to be regarded for corporation tax purposes as a separate trade.

7

For this purpose “short-term insurance business” means any insurance business which is not long-term business.

C267Exception where BLAGAB small part of long-term business

1

There is an exception to the general rule set out in section 66(1) if for an accounting period of an insurance company substantially all of its long-term business is not basic life assurance and general annuity business.

2

In that case, there is for the accounting period to be no separate business consisting of the company's basic life assurance and general annuity business.

3

There is instead to be one business that is to be regarded for corporation tax purposes as a single trade of the company consisting of its long-term business.

4

That single trade is to be regarded as “non-BLAGAB long-term business” for the purposes of this Part.

5

Accordingly, references in this Part (apart from in section 66 and this section) to a company's basic life assurance and general annuity business do not include any business which, as a result of this section, is regarded as non-BLAGAB long-term business.