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Where the profits of a controlled foreign company fall to be apportioned on a United Kingdom resident company

• which carries on a life assurance business in the accounting period in which the accounting period of the controlled foreign company ends, and
• the property or rights constitute to any extent assets of the United Kingdom company’s long term business fund, and
• the United Kingdom company is not charged to tax in respect of its profits from life assurance, then

the appropriate rate for the purposes of ICTA88/S747(4)(a) and ICTA88/SCH24/PARA1 will be as follows:-

(i) In relation to the policy holders� part of any basic life assurance and general annuity business (“BLAGAB�) apportioned profit the appropriate rate is whatever single rate tax is already applicable in relation to the relevant accounting period.

(ii) »Ê¹ÚÌåÓýapp appropriate rate is nil in relation to so much of the apportioned profit as is referable to:

pension business,

life reinsurance business, or

overseas life assurance business,

carried on by the United Kingdom company.