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FA12/S57(2) defines BLAGAB as anything other than the categories of business listed at S57(2)(a)-(g). Included in that list is

‘reinsurance of life assurance business other than excluded business�

Where a reinsurer writes excluded business, it is treated as BLAGAB and the reinsurer must apply the I-E rules to the income and gains relating to the business reinsured unless FA12/S67 applies as the business is substantially non-BLAGAB.

Where the reinsurance of BLAGAB is not ‘excluded business� all of the profits will be subject to the normal corporation tax rules and no special rules apply.

Regulations implemented under the powers in S57(3) define excluded business

• for reinsurance arrangements entered into on or after 1st June 2018 ‘The Insurance Companies (Taxation of Re-insurance Business) Regulations 2018â€� (SI2018/538).
• for reinsurance arrangements entered into on or after 29 November 1995 but before 1st June 2018 Insurance Companies (Taxation of Reinsurance Business) Regulations 1995 (SI1995/1730).

Note that following the introduction of the FA12 regime, the 1995 regulations were not repealed and continued to apply to business written up to 1st June 2018 FA12/S57 and S90. That follows from the transitional rules in FA12/SCH17/PARA36. This guidance does not consider the effect of the primary legislation which applied prior to FA12. Detailed guidance on the rules in SI1995/1730, amended by SI2003/2573, can be found at onwards.