81(1)An unused pension business loss of an insurance company (see sub-paragraph (4)) is to be treated as if it were a loss incurred by the company on its gross roll-up business in the period of account immediately preceding the commencement period.U.K.
(2)Subsections (4) and (5) of section 436A of ICTA accordingly apply to the loss, but subject to sub-paragraph (3) (and to subsection (7) of that section).
(3)The amount by which the company's profits charged under that section in a period of account is to be treated as reduced under subsection (4)(b) of that section by virtue of this paragraph must not exceed—
where—
“CP” is the amount of the company's profits chargeable under that section in the period of account,
“PBL” is the mean of the opening and closing liabilities of the company's pension business for the period of account, and
“GRBL” is the mean of the opening and closing liabilities of the company's gross roll-up business for the period of account.
(4)In this paragraph “unused pension business loss”, in relation to an insurance company, means so much of any losses incurred by the company on its pension business in any pre-commencement period as were not set off under section 436(3)(c) of ICTA against profits in any such period.