Double Taxation Relief Life Insurance Companies

I was preparing some notes for a client on how to calculate the restriction on the amount available for double taxation taxation credit relief when the associated foreign income is included in a trading profits computation.  The legislation for this is now in  sections  99 -104  TIAOPA 2010.

For the purposes of credit relief the relevant foreign income has to be reduced by an amount of "total relevant expenses" determined by applying a formula of RI/TI to total relevant expenses where RI is relevant income and TI total income.

Relevant expenses and total income are both defined terms in the legislation and pre FA 2012 were derived from the FSA returns in accordance with TIAOPA 2010 section 102.  So I turned to section 102 to see how this legislation had been updated post 2012.  But section 102 had been repealed - my first thought was this looked like something that had gone astray during the 2012 redraft and the terms relevant expenses and total income had lost their definition.

Fortunately this is not the case(oh me of little faith).  The definitions are in the new legislation and they have been updated so that they now refer to information in statutory accounts rather than FSA returns. However, the definition section has now moved to TIAOPA 2010 section 103.  Might just save you looking for it.