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Apportionment of expenses, allowances and donations in respect of income derived before 1 July 2021

Income Tax (Exemption and Concessionary Tax Rate for Income from Life Insurance Business) Regulations

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—(1) For the purpose of determining the income mentioned in regulation 4(1), any item of expenditure not directly attributable to the offshore life business of an approved insurer, and capital allowances and donations, allowable to the approved insurer under the Act, shall be apportioned between such business and the other life insurance business of the approved insurer; and the portion attributable to such business shall be ascertained by using the fraction —where Po and Pi have the same meanings as in regulation 5.(2) For the purpose of determining the income mentioned in regulation 5A(1), any item of expenditure not directly attributable to the offshore captive insurance business or the offshore life business of such insurer, as well as any capital allowances and donations allowable to such insurer under the Act, are to be apportioned between such business and the other insurance business of such insurer in the following manner:(a)the portion attributable to offshore captive insurance business is to be ascertained by using the fraction —(b)the portion attributable to offshore life business, other than offshore captive insurance business, is to be ascertained by using the fraction —wherePc has the same meaning as in regulation 5A; and Po and Pihave the same meaning as in regulation 5(1).(3) The Comptroller may apply any alternative method of apportionment in place of any of the prescribed fractions in paragraphs (1) and (2) if the Comptroller is satisfied that the alternative method is reasonable in the circumstances of the business of the approved insurer.

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