Draft Taxation Determination

TD 93/D257

Income tax: insurance: in the calculation of the amount deductible for the general management expenses of a life assurance company, should assessable income and total income for subsection 113(2) purposes include amounts that relate to the conduct of general insurance business?

  • Please note that the PDF version is the authorised version of this draft ruling.
    This document has been finalised by TD 94/12.

FOI status:

draft only - for comment

Preamble

Draft Taxation Determinations (TDs) present the preliminary, though considered, views of the ATO. Draft TDs may not be relied on; only final TDs are authoritative statements of the ATO.

1. Yes. In the calculation of the amounts that are deductible under subsection 113(2), the amounts to be taken into account in the formula assessable income over total income should include the assessable income and total income 'of the company.' Accordingly if a life assurance company also conducts general insurance business (or any other business), providing that it carries on the principal business of life assurance, assessable income and total income in the formula for subsection 113(2) purposes must include the income from all sources, that is from each business.

Commissioner of Taxation
30 September 1993

References


BO Insurance Industry Cell

ISSN 1038 - 8982

Subject References:
Australian life assurance companies
general management expenses

Legislative References:
ITAA 113(2)

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