Commentary

D7.423 Insurance special purpose vehicles – BLAGAB group reinsurers

Corporate tax
Corporate tax | Commentary

D7.423 Insurance special purpose vehicles – BLAGAB group reinsurers

Corporate tax | Commentary

D7.423 Insurance special purpose vehicles – BLAGAB group reinsurers

The rules in this division apply for accounting periods beginning on or after 1 January 2013. For accounting periods beginning before 1 January 2013 see Division D7.5.

In contrast the tax rules need to cater for ISPVs that reinsure BLAGAB from fellow group companies (called 'BLAGAB group reinsurers' in the legislation) and which are taxable on the I-E basis.

As such the life assurance taxation provisions in FA 2012, Pt 2 apply in full to such a company provided that:

  1.  

    (a)     it carries on BLAGAB

  2.  

    (b)     it does not write all, or substantially

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