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PART 2Insurance companies carrying on long-term business

CHAPTER 3The I - E basis

Non-BLAGAB allowable losses

95Use of non-BLAGAB allowable losses to reduce I - E profit

(1)This section applies if—

(a)an insurance company has an I - E profit for an accounting period, and

(b)non-BLAGAB allowable losses have accrued to the company that are available for deduction in accordance with section 210A(2) of TCGA 1992 from the shareholders’ share of BLAGAB chargeable gains that have accrued to the company.

(2)Those losses may be deducted from those gains in accordance with that provision so as to reduce the amount of the I - E profit for the accounting period to nil but no further.

(3)For the purposes of subsection (1)(a), assume that non-BLAGAB allowable losses cannot be deducted from any BLAGAB chargeable gains (and, accordingly, ignore the effect of this section).