GIM12000 - Double taxation relief

This section describes the treatment of foreign tax suffered by companies carrying on general insurance business.

1. GIM12010

   Background: types of foreign tax suffered
2. GIM12020

   Background: Double Taxation Conventions
3. GIM12030

   Background: residence and similar certificates
4. GIM12040

   Background: no relief for "company tax deducted"
5. GIM12050

   Overseas branch profits: calculation
6. GIM12060

   Overseas branch profits: foreign taxes on UK insurers where there is no "permanent establishment": background
7. GIM12070

   Overseas branch profits: foreign taxes on UK insurers where there is no "permanent establishment": premium taxes
8. GIM12080

   Overseas branch profits: foreign taxes on UK insurers where there is no "permanent establishment": admissibility for credit
9. GIM12090

   Overseas branch profits: foreign taxes on UK insurers where there is no "permanent establishment": "treaty carve out"
10. GIM12100

    Overseas branch profits: foreign taxes on UK insurers: deemed "permanent establishment"
11. GIM12110

    Overseas branch profits: creditability of taxes on branch profits: OECD Article 7
12. GIM12120

    Underlying tax on dividends referable to an overseas branch: accounting periods beginning before 1 April 2000
13. GIM12130

    Underlying tax on dividends referable to an overseas branch: accounting periods beginning before 1 April 2000: restriction of credit under section 802 ICTA 1988
14. GIM12140

    Underlying tax on dividends referable to an overseas branch: accounting periods beginning before 1 April 2000: restriction of credit under section 802 ICTA 1988: example
15. GIM12150

    Underlying tax on dividends referable to an overseas branch: accounting periods beginning before 1 April 2000: section 802 ICTA and Extra-Statutory Concession C1(b)
16. GIM12160

    Underlying tax on dividends referable to an overseas branch: accounting periods beginning before 1 April 2000: section 802 ICTA & ESC C1(b): information
17. GIM12170

    Foreign tax on other income: accounting periods beginning before 1 April 2000
18. GIM12180

    General rules for accounting periods beginning on or after 1 April 2000
19. GIM12190

    General rules for accounting periods beginning on or after 1 April 2000: income and gains not referable to insurance business
20. GIM12200

    Foreign tax on investment income: accounting periods beginning on or after 1 April 2000: section 804C ICTA 1988
21. GIM12210

    Foreign tax on investment income: accounting periods beginning on or after 1 April 2000: section 804C ICTA 1988: limitation of relevant income
22. GIM12220

    Foreign tax on investment income: accounting periods beginning on or after 1 April 2000: section 804C ICTA 1988: the first limitation - for expenses
23. GIM12230

    Foreign tax on investment income: accounting periods beginning on or after 1 April 2000: section 804C ICTA 1988: the first limitation: example
24. GIM12240

    Foreign tax on investment income: accounting periods beginning on or after 1 April 2000: section 804C ICTA 1988: meaning of “total relevant expenses” and “total income”
25. GIM12250

    Foreign tax on investment income: accounting periods beginning on or after 1 April 2000: section 804C ICTA 1988: the first limitation: shortcut
26. GIM12260

    Foreign tax on investment income: accounting periods beginning on or after 1 April 2000: section 804C ICTA 1988: the second limitation: purpose of section 804C(4)
27. GIM12270

    Foreign tax on investment income: accounting periods beginning on or after 1 April 2000: section 804C ICTA 1988: the second limitation: section 804C(4) calculation
28. GIM12280

    Foreign tax on investment income: accounting periods beginning on or after 1 April 2000:: section 804C ICTA 1988: the second limitation: example
29. GIM12290

    Foreign tax on investment income accounting periods beginning on or after 1 April 2000: section 804C ICTA 1988: limitations applied to a non-insurance subsidiary
30. GIM12300

    Foreign tax on investment income: accounting periods beginning on or after 1 April 2000: section 804C ICTA 1988: interaction of credit relief and relief as expense