GIM5000 - Taxation of the investment return
This section covers one of the more unusual features of the taxation of general insurers, namely the treatment of investment income and gains. See GIM4000+ for the broad framework of the taxation of general insurance.
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GIM5010General overview
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GIM5020The general rule: investment income treated as trading receipt
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GIM5030Exceptions to the general rule: investment income not always taxed as trade profits
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GIM5040UK dividends and other distributions: history and basic rule
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GIM5050UK dividends and other distributions exemption: dividend stripping: distributions made before 1 April 2008
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GIM5055UK dividends and other distributions exemption: dividend stripping: distributions made on or after 1 April 2008: preference share lending
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GIM5060Interest and foreign dividends
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GIM5070Interest and foreign dividends: income received under deduction of tax
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GIM5080Use of trading losses against investment income
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GIM5090Corporate and government debt: accounting periods ending after 31 March 1996: introduction
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GIM5100Corporate and government debt: accounting periods ending after 31 March 1996: rules for insurance companies
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GIM5110Corporate and government debt: exchange differences: accounting periods ending after 31 March 1996 and beginning before 1 October 2002
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GIM5120Corporate and government debt: exchange differences: accounting periods ending after 31 March 1996 and beginning on or after 1 October 2002
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GIM5130Financial instruments: accounting periods beginning before 1 October 2002
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GIM5140Derivative contracts: accounting periods beginning on or after 1 October 2002
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GIM5150Investment gains: accounting periods beginning before 1 January 2002: gains and losses on equities and other non-debt assets
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GIM5160Investment gains: accounting periods beginning before 1 January 2002: portfolio assets and trading stock
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GIM5170Investment gains: accounting periods beginning before 1 January 2002: portfolio assets and trading stock: periods ending before 1 April 1996
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GIM5180Investment gains: accounting periods beginning before 1 January 2002: the realisations basis
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GIM5190Investment gains: accounting periods beginning on or after 1 January 2002: transition from realisation basis: change of accounting basis
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GIM5200Investment gains: accounting periods beginning on or after 1 January 2002: transition from realisation basis: transitional measures
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GIM5210Investment gains: accounting periods beginning on or after 1 January 2002: transition from realisation basis: transfers of business
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GIM5220Investment gains: accounting periods beginning on or after 1 January 2002: transition from realisation basis: identification of part realisations
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GIM5230Investment gains: structural assets
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GIM5240Investment gains: paper for paper exchange of assets
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GIM5250Investment gains: paper for paper exchange of assets: section 473 ICTA 1988
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GIM5260Investment gains: portfolio assets: anti avoidance provisions
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GIM5270Investment gains: portfolio assets: exchange differences
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GIM5280Investment gains: land and property