11 There shall be excluded from section 431C any reinsurance business where–
(a)in relation to the reinsurance arrangement–
(i)the cedant company is a 90% subsidiary of the reinsurer, or the reinsurer is a 90% subsidiary of the cedant company, or each is a 90% subsidiary of another body corporate,
(ii)the cedant company is either resident in the United Kingdom or is an overseas life insurance company which, as respects the reinsurance arrangement or, as the case may be, the business being reinsured, is within the charge to corporation tax by virtue of section 11 of the Taxes Act, and
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