46U.K.After paragraph 11 of Schedule 19AC to the Taxes Act 1988 insert—
“11A(1)In section 441A, the following subsection shall be treated as inserted after subsection (1)—
”(1A)The exclusion from section 11(2)(a), (aa) and (ab) of distributions received from companies resident in the United Kingdom shall not apply in relation to a distribution in respect of any asset of the overseas life assurance fund of an overseas life insurance company.”.
(2)The following subsection shall be treated as substituted for subsections (2) and (3) of that section—
”(3)An overseas life insurance company shall be entitled to a tax credit in respect of a distribution which—
(a)is a distribution in respect of an asset of the company’s overseas life assurance fund, and
(b)is received from a company resident in the United Kingdom,
if and to the extent that regulations made by the Board so provide.”.
11BIn section 442A the following subsection shall be treated as inserted after subsection (6)—
”(7)In the case of an overseas life insurance company, the investment return treated as accruing under this section in any accounting period in relation to a policy or contract shall be treated as chargeable profits within section 11(2) of the Taxes Act 1988 where the policy or contract is one which in that accounting period gives rise, or but for the reinsurance arrangement would give rise, to such profits.”.”