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