SCHEDULE 11Loan relationships: special provisions for insurers
Part IInsurance companies
I minus E basis
1
(1)
Nothing in this Chapter shall be construed as preventing profits and gains arising from loan relationships of an insurance company from being included, where—
(a)
the relationship is referable to any life assurance business or capital redemption business carried on by the company, and
(b)
that business is business in respect of which the I minus E basis is applied,
in profits and gains on which the company is chargeable to tax in accordance with that basis.
(2)
Where, for any accounting period, the I minus E basis is applied in respect of any life assurance business or capital redemption business carried on by an insurance company, the effect of applying that basis shall be—
(a)
that none of the credits or debits falling for the purposes of this Chapter to be brought into account in respect of loan relationships of the company that are referable to that business shall be brought into account as mentioned in section 82(2) of this Act; but
(b)
that (subject to the following provisions of this Schedule) all those credits and debits shall, instead, be brought into account, in applying that basis to that business, as non-trading credits or, as the case may be, non-trading debits;
and the reference in paragraph 2(1) below to non-trading credits and non-trading debits shall be construed accordingly.