SCHEDULES
SCHEDULE 20Controlled foreign companies and foreign permanent establishments
PART 2Foreign permanent establishments
Lloyd's underwriters
8
In Chapter 5 of Part 4 of FA 1994 (Lloyd's underwriters) after section 227B insert—
227CExemption for profits or losses of foreign permanent establishments
1
This section applies for the purposes of section 18A(6) and (7) of the Corporation Tax Act 2009 (exemption for profits or losses of foreign permanent establishments: “relevant profits amount” and “relevant losses amount”).
2
Any regulations made under section 229(1)(d) below are to be ignored.
3
Profits or losses which are taken to arise to a corporate member in an underwriting year from its membership of one or more syndicates are to be left out of account in relation to any relevant accounting period so far as they are profits or losses of a previous underwriting year which began before the relevant day (as defined in section 18F of the 2009 Act (effect of election under section 18A)).
4
Profits or losses arising to a corporate member from assets forming part of a premium trust fund which are taken to be profits or losses of an underwriting year are to be left out of account in relation to any relevant accounting period so far as they are allocated under the rules or practice of Lloyds to a previous underwriting year which began before the relevant day (as defined in section 18F of the 2009 Act).