Commentary

D7.445 Equities—share pooling

Corporate tax
Corporate tax | Commentary

D7.445 Equities—share pooling

Corporate tax | Commentary

D7.445 Equities—share pooling

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.

Given the significant equity holdings of life insurance companies, the share pooling rules are of particular importance and are modified to deal with the particular circumstances of the equity holdings of such companies1.

The legislation identifies five separate pools that may potentially exist:

  1.  

    (a)     securities matched to BLAGAB liabilities,

  2.  

    (b)     securities matched to other long-term liabilities,

  3.  

    (c)     securities held for the purposes of any with-profits fund but which are not matched to

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