770-135 Apportionment of a CFC’s profits: life assurance companies
For periods within self-assessment (accounting periods ending after 30 June 1999) there are special provisions which deal with the treatment of chargeable profits and creditable tax of a CFC apportioned to life companies. These provisions are designed to reflect the tax which would have been charged on the life company had the CFC’s profits been repatriated to the UK by way of dividends.
The Finance Act 1998 introduced a provision to deal with the situation where (ICTA 1988, s. 755A):
(1)a UK company carries on life assurance business in one of its accounting periods (‘the relevant accounting period’) in which the CFC’s accounting period ends;