{
  "url": "https://openlegislation.uk/finance-act-2009/schedule-23/paragraph-2",
  "json_url": "https://openlegislation.uk/finance-act-2009/schedule-23/paragraph-2.json",
  "legislation": "ukpga/2009/10",
  "legislation_title": "Finance Act 2009",
  "legislation_url": "https://openlegislation.uk/finance-act-2009",
  "path": "schedule/23/paragraph/2",
  "kind": "paragraph",
  "number": "2",
  "heading": null,
  "text": "(1) In section 82 of FA 1989 (calculation of profits), after subsection (2) insert—\n“(2A) But amounts are not allowed as such a deduction if they—\n(a) are allocated to holders of policies under which they are eligible to participate in surplus,\n(b) are of a capital nature, and\n(c) are not funded from amounts brought into account as part of total income in line 19 of the revenue account prepared for the purposes of Chapter 9 of the Prudential Sourcebook (Insurers) in respect of the whole of the company's long-term business.\n(2B) For the purposes of subsection (2A) above payments made in connection with the reattribution of inherited estate are to be regarded as being of a capital nature.”\n(2) The amendment made by sub-paragraph (1) has effect in relation to amounts allocated on or after 22 April 2009 to holders of policies under which they are eligible to participate in surplus.",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2009/10/schedule/23/paragraph/2",
    "retrieved_at": "2026-10-29T09:11:08.872832+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}