Commentary

D7.454 Transfers of assets between categories under an insurance business transfer scheme

Corporate tax
Corporate tax | Commentary

D7.454 Transfers of assets between categories under an insurance business transfer scheme

Corporate tax | Commentary

D7.454 Transfers of assets between categories under an insurance business transfer scheme

Where an asset is transferred under an insurance business transfer scheme and is in a different category before and after the transfer, the transferor is deemed to have disposed of the asset at fair value immediately before its acquisition by the transferee1. In this context fair value is defined as the amount which would be obtained from an independent person purchasing the asset(s) or if the asset is money, its amount2.

The different categories of business to which these rules apply are:

  1.  

    (a)     the long-term business categories (as set

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