Corporation Tax Act 2010 section 269ZFC

Restriction on deductions of non-BLAGAB allowable losses from BLAGAB chargeable gains

Section 269ZFC limits how much of an insurance company's non-BLAGAB (basic life assurance and general annuity business) capital losses can be set against the shareholders' share of BLAGAB chargeable gains in any accounting period.

• Non-BLAGAB allowable losses deducted from the shareholders' share of BLAGAB chargeable gains cannot exceed the "relevant maximum" for the accounting period
• The relevant maximum is 50% of the company's relevant BLAGAB chargeable gains plus its BLAGAB deductions allowance for the period
• The BLAGAB deductions allowance is the portion of the company's overall deductions allowance that it nominates for this purpose in its tax return, and is nil if no amount is specified
• The BLAGAB deductions allowance cannot exceed the company's overall deductions allowance less any amounts already allocated to trading profits, general chargeable gains, and non-trading income profits deductions allowances

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