The allocation of assets for tax purposes to OLAB has always been complicated. Income and gains on assets allocated to OLAB are not included within the BLAGAB I-E income and gains but are instead used in the OLAB/GRB profit calculation. The abolition of the ‘overseas life assurance fund’ for accounting periods beginning on or after 1 January 2007 introduced the concept of ‘foreign currency assets’, the income and gains on which were allocated to GRB. To treat assets held by the company as ‘foreign currency assets’ required the assets either

to be managed by a person working at a permanent establishment outside the UK; or

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