LLM7170 - Double taxation relief: corporate members: Regulations: foreign measure of profit

Where Lloyd’s has a central agreement or arrangement to deal with taxes in overseas territories HMRC will accept that, in determining the extent to which credit for foreign tax may be given, the foreign measure of profit under those arrangements can also be taken as the measure of relevant income for the purposes of ICTA88/S797 and to have satisfied the provisions of ICTA88/S795A.

The territories for which there are such arrangements are:

AustraliaJapan
BelgiumMalta
CanadaNew Zealand
DominicaSt Lucia
FranceSt Vincent and the Grenadines
French PolynesiaSingapore
Hong KongUnited States of America
Israel