Commentary

D7.455 Transfers of assets between companies

Corporate tax
Corporate tax | Commentary

D7.455 Transfers of assets between companies

Corporate tax | Commentary

D7.455 Transfers of assets between companies

If a life insurance company acquires or disposes of an asset within the categories of assets held for its long-term business (as set out in D7.453 above) the rules for intra-group transactions in TCGA 1992, ss 171 and 173 (which generally ensure a no gain/no loss transfer) are disapplied1.

Similarly the rules in TCGA 1992, s 171A which permit companies within the same capital gains group to elect to reallocate gains and losses between themselves are more restricted in scope when one of the parties to the election is a life insurance company. If Company

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