Exclusion of certain reinsurance business from section 439A
12. There shall be excluded from section 439A any reinsurance business carried on by a company (“the reinsurer”) whose reinsurance business is limited to arrangements where—
(a)the cedant company is a 90% subsidiary of the reinsurer, or the reinsurer is a 90% subsidiary of the cedant company, or each is a 90% subsidiary of another body corporate, and
(b)the cedant company either—
(i)is resident in the United Kingdom, or
(ii)is not so resident but, as respects all the business reinsured with the reinsurer, is within the charge to corporation tax by virtue of section 11 of the Taxes Act.