464(1)Amend section 171 (Lloyd's underwriters etc: taxation of income tax profits) as follows.U.K.
(2)In subsection (2) for paragraphs (a) and (b) substitute—
“(a)the aggregate of those profits shall be chargeable to tax under Chapter 2 of Part 2 of the Income Tax (Trading and Other Income) Act 2005 as the profits of a trade carried on in the United Kingdom; and
(b)accordingly, no part of those profits shall be treated as relevant foreign income, or be charged to tax under any other Part of that Act or any Part of the Income Tax (Earnings and Pensions) Act 2003;”.
(3)In subsection (2B) for “section 231(1) of the Taxes Act 1988” substitute “ section 397(1) of the Income Tax (Trading and Other Income) Act 2005 ”.