FA12/S139(1)

An overseas life insurance company (OLIC) with a permanent establishment (PE) in the UK is subject to corporation tax on the profits arising from the PE in the same way as other companies CTA09/S5

There are a small number of special provisions in the legislation as well as specific OECD guidance on attribution of profits to an insurance PE. The latter are explained in more detail in the General Insurance Manual (GIM10000 onwards).

This section sets out the life insurance specific provisions and considerations for non-resident insurance companies with a UK PE.

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