Taxes Consolidation Act 1997 section 729

Income tax, foreign tax and tax credit

Section 729 restricts the relief available to an overseas life assurance company for foreign tax suffered and limits the amount of income tax that may be set off against its corporation tax liability.

• No deduction is allowed for foreign tax when computing the investment income of the life assurance fund, the profits of the annuity business, or chargeable gains on disposal of investments of an overseas life assurance company.
• The right of an overseas life assurance company to set off income tax deducted from payments it receives against its corporation tax liability is restricted.
• Where corporation tax on investment income of the life assurance fund is charged on a proportionate basis under section 726, the income tax set-off is capped at income tax at the standard rate on the proportion of investment income so chargeable.
• Where corporation tax on general annuity business profits is charged on a proportionate basis under section 727, the income tax set-off is capped at income tax at the standard rate on the like proportion of investment income included in computing those profits.