Introduction Limits on loss relief for addition to non-profits funds
5.Paragraph 3(1) inserts into the Income and Corporation Taxes Act 1988 (ICTA) new sections 434AZA, 434AZB and 434AZC.
6.New section 434AZA restricts the Case I loss of the company’s life assurance business available to set off against the company’s other income of the accounting period or to surrender as group relief when:
	there has been an addition to a non profit fund of the company; and, in that period of account or a subsequent period of account,
	the company has made a book value election in respect of a non-profit fund or funds; and/or
	arrangements have been entered into the purpose or main purpose of which is to reduce the admissible value of the assets of a non-profit fund or funds.
7.New section 434AZB determines the extent to which the Case I loss is to be restricted. The restriction in respect of a period of account is the least of:
8.When a loss arising in a period of account has been restricted there will be a corresponding reduction in the amounts available to restrict losses in subsequent periods of account.
9.New section 434AZC contains supplementary provisions. Subsection (2) applies section 434AZA and 434AZB to a non-profit part of a with-profit fund. The non-profit part of a with-profit fund is that part of the with-profit fund which belongs to the company and in whose profits the with-profits policyholders are not entitled to participate. The subsection ensures that for this purpose it is treated in the same way as a non-profit fund.