Taxes Consolidation Act 1997 section 727

General annuity and pension business

Section 727 sets out rules for computing the taxable profits of an overseas life assurance company from its general annuity business and pension business carried on through an Irish branch.

• Distributions from Irish-resident companies must be included when computing the overseas life assurance company's profits from pension business and general annuity business.
• Only a portion of worldwide general annuity business profits is chargeable to Irish corporation tax, determined by the formula (A × B) ÷ C, where A is total profits, B is average liabilities under Irish-connected contracts, and C is average liabilities under all general annuity contracts.
• Liabilities are ascertained by reference to the net liabilities as valued by an actuary for the purposes of the relevant periodical insurance return.
• The average of liabilities for an accounting period is 50 per cent of the sum of the opening and closing liability figures for the valuation period that coincides with, or includes, that accounting period.