PART 2Insurance companies carrying on long-term business

CHAPTER 9Relief for BLAGAB trade losses etc

The reliefs

F1124ACarry forward of post-1 April 2017 BLAGAB trade losses against subsequent profits

(1)

This section applies if—

(a)

an insurance company carrying on basic life assurance and general annuity business makes a BLAGAB trade loss for an accounting period beginning on or after 1 April 2017 (“the loss-making period”),

(b)

relief under—

  • section 37 of CTA 2010 (as applied by section 123), or

  • Part 5 of CTA 2010 (group relief) (as applied by section 125),

is not given for an amount of the loss (“the unrelieved amount”), and

(c)

the company continues to carry on basic life assurance and general annuity business in the next accounting period (“the later period”).

(2)

The unrelieved amount is carried forward to the later period.

(3)

Relief for the unrelieved amount is given to the company in the later period if the company has a BLAGAB trade profit for the later period.

(4)

The relief is given as set out in subsection (5).

(5)

For the purposes of—

(a)

section 93 (minimum profits charge), and

(b)

section 104 (policyholders' rate of tax),

the BLAGAB trade profit of the later period is reduced by the unrelieved amount F2....

(6)

Relief under this section is subject to restriction or modification in accordance with section 137(7) of CTA 2010 and other applicable provisions of the Corporation Tax Acts.