LAM06030 - I-E Profit: Calculation of the tax charge: Determining the policyholders� share of I-E profit: meaning of the adjusted amount: FA12/S104

In FA12/S103 a comparison is made between the I-E profit and the adjusted amount of BLAGAB trade profit for the period in order to calculate the policyholders� share of the I-E profit (if any).

»Ê¹ÚÌåÓýapp adjusted amount of BLAGAB trade profit (FA12/S104) is calculated as:

  • the BLAGAB trade profit (see LAM07200) less;
  • brought forward BLAGAB trade losses, and then if necessary, further reduced by;
  • the shareholdersâ€� share of BLAGAB non-taxable distributions (“BNTDâ€�) as calculated under FA12/S105 (see LAM06040)

»Ê¹ÚÌåÓýapp adjusted amount of BLAGAB trade profit cannot be a negative. »Ê¹ÚÌåÓýapprefore if the BLAGAB trade profit is reduced to nil by the brought forward losses, there is no need to make a further adjustment by deducting the BNTD. For periods beginning between 1 April 2017 and 5 July 2018 the set-off of carried forward trade losses is restricted (LAM15210). For periods beginning before 1 April 2017 or beginning on or after 6 July 2018 the set-off of carried BLAGAB trade losses against BLAGAB trade profits is not restricted.

»Ê¹ÚÌåÓýapp effect of reducing the BLAGAB trade profit by the brought forward BLAGAB trade losses is to reduce the shareholdersâ€� share of the I-E profit in the period.

»Ê¹ÚÌåÓýapp reason for reducing the BLAGAB trade profit by the shareholdersâ€� share of BNTD (see LAM06040) is to allow for a proper comparison to be made between the I-E profit and the BLAGAB trade profit. Distributions are brought into the BLAGAB trade profit calculation but not in the I-E calculation so they must be removed from the BLAGAB trade computation for the purposes of the comparison.