PART 2Insurance companies carrying on long-term business

CHAPTER 3The I - E basis

Special rules applying to I - E basis

86Separate property businesses for BLAGAB etc

1

This section modifies the rules in sections 208 and 209 of CTA 2009 (basic meaning of UK and overseas property business) for the purpose of applying the I - E rules in relation to an insurance company.

2

The company is treated as carrying on separate UK property businesses or overseas property businesses in accordance with the following provisions.

3

The exploitation of land held otherwise than for the purposes of the company’s long-term business is treated as a separate business from the exploitation of land held for those purposes.

4

In the case of the exploitation of land held for the purposes of the company’s long-term business, each of the following is treated as a separate business—

a

the exploitation of land which is matched to BLAGAB liabilities of the company,

b

the exploitation of land which is matched to other long-term business liabilities of the company, and

c

the exploitation of land so far as it is not matched to long-term business liabilities of the company.

5

In the case of land part of which is matched to a BLAGAB liability or other long-term business liability, only the part of the land in question is to count for the purposes of this section as matched to the liability in question.

6

In this section “land” means any estate, interest or right in or over land.