Life insurance companies are entitled to relief for foreign tax suffered, subject to the rules in Part 2 of TIOPA10 (see INTM160000). Foreign tax will generally be either:

overseas tax on non-UK income, such as dividends, interest, rent etc., or

tax paid in relation to profits of an overseas branch

This chapter references some of the general rules in Part 2 of TIOPA10 that need particular consideration for life companies as well as variations to those rules specific to insurance companies in TIOPA10/S96 to S104.

The rationale for the differences and the main provisions to consider are:

Relating foreign tax to I-E profit and non-BLAGAB trade profit

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