Commentary

D4.429 CFC gateway: captive insurance business

Corporate tax
Corporate tax | Commentary

D4.429 CFC gateway: captive insurance business

Corporate tax | Commentary

D4.429 CFC gateway: captive insurance business

It is necessary to firstly establish in what situations this gateway test applies and then if it does, the extent to which profits pass through the gateway. Only profits which pass through the gateway are potentially liable to the CFC charge.

Establishing whether the test applies

This gateway test applies if at any time during the accounting period, the main part of the CFCs business is insurance business and the CFCs assumed total profits (see D4.420) include amounts which derive from insurance contracts entered into with1:

  1.  

    •     a UK resident company, which is connected2 with

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