GIM12000 - Double taxation relief


This section describes the treatment of foreign tax suffered by companies carrying on general insurance business.

GIM12010Background: types of foreign tax suffered
GIM12020Background: Double Taxation Conventions
GIM12030Background: residence and similar certificates
GIM12040Background: no relief for “company tax deducted”
GIM12050Overseas branch profits: calculation
GIM12060Overseas branch profits: foreign taxes on UK insurers where there is no “permanent establishment”: background
GIM12070Overseas branch profits: foreign taxes on UK insurers where there is no “permanent establishment”: premium taxes
GIM12080Overseas branch profits: foreign taxes on UK insurers where there is no “permanent establishment”: admissibility for credit
GIM12090Overseas branch profits: foreign taxes on UK insurers where there is no “permanent establishment”: “treaty carve out”
GIM12100Overseas branch profits: foreign taxes on UK insurers: deemed “permanent establishment”
GIM12110Overseas branch profits: creditability of taxes on branch profits: OECD Article 7
GIM12120Underlying tax on dividends referable to an overseas branch: accounting periods beginning before 1 April 2000
GIM12130Underlying tax on dividends referable to an overseas branch: accounting periods beginning before 1 April 2000: restriction of credit under section 802 ICTA 1988
GIM12140Underlying tax on dividends referable to an overseas branch: accounting periods beginning before 1 April 2000: restriction of credit under section 802 ICTA 1988: example
GIM12150Underlying tax on dividends referable to an overseas branch: accounting periods beginning before 1 April 2000: section 802 ICTA and Extra-Statutory Concession C1(b)
GIM12160Underlying tax on dividends referable to an overseas branch: accounting periods beginning before 1 April 2000: section 802 ICTA & ESC C1(b): information
GIM12170Foreign tax on other income: accounting periods beginning before 1 April 2000
GIM12180General rules for accounting periods beginning on or after 1 April 2000
GIM12190General rules for accounting periods beginning on or after 1 April 2000: income and gains not referable to insurance business
GIM12200Foreign tax on investment income: accounting periods beginning on or after 1 April 2000: section 804C ICTA 1988
GIM12210Foreign tax on investment income: accounting periods beginning on or after 1 April 2000: section 804C ICTA 1988: limitation of relevant income
GIM12220Foreign tax on investment income: accounting periods beginning on or after 1 April 2000: section 804C ICTA 1988: the first limitation - for expenses
GIM12230Foreign tax on investment income: accounting periods beginning on or after 1 April 2000: section 804C ICTA 1988: the first limitation: example
GIM12240Foreign tax on investment income: accounting periods beginning on or after 1 April 2000: section 804C ICTA 1988: meaning of “total relevant expenses” and “total income”
GIM12250Foreign tax on investment income: accounting periods beginning on or after 1 April 2000: section 804C ICTA 1988: the first limitation: shortcut
GIM12260Foreign tax on investment income: accounting periods beginning on or after 1 April 2000: section 804C ICTA 1988: the second limitation: purpose of section 804C(4)
GIM12270Foreign tax on investment income: accounting periods beginning on or after 1 April 2000: section 804C ICTA 1988: the second limitation: section 804C(4) calculation
GIM12280Foreign tax on investment income: accounting periods beginning on or after 1 April 2000:: section 804C ICTA 1988: the second limitation: example
GIM12290Foreign tax on investment income accounting periods beginning on or after 1 April 2000: section 804C ICTA 1988: limitations applied to a non-insurance subsidiary
GIM12300Foreign tax on investment income: accounting periods beginning on or after 1 April 2000: section 804C ICTA 1988: interaction of credit relief and relief as expense


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