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Taxation (International and Other Provisions) Act 2010

Section 99: Allocation of expenses etc in calculations under section 35 of CTA 2009

224.This section sets out rules for setting an insurance company’s expenses and other deductions against items of income to calculate the measure of income, and therefore of corporation tax in respect of it, against which the creditability of foreign tax is to be measured. It is based on section 804C(1), (2), (5) and (10) to (13) of ICTA.

225.Under subsection (1)(b), this section only applies if a calculation falls to be made in accordance with the provisions applicable for the purposes of section 35 of CTA 2009.

226.Under subsection (2), the amount of credit for foreign tax is restricted, first in accordance with section 100 and then (if relevant) by section 101.

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