Commentary

D7.486 Transfers of insurance business between non-group companies

Corporate tax
Corporate tax | Commentary

D7.486 Transfers of insurance business between non-group companies

Corporate tax | Commentary

D7.486 Transfers of insurance business between non-group companies

There is no need for special rules in the case of transfers of insurance business between companies that are not members of the same group. In such circumstances the parties will be taxed by reference to the profit or loss on the transfer that appears in their statutory accounts in the same way as for any commercial transaction between unconnected parties.

When considering whether parties to an insurance business transfer are members of the same group, the definition in TCGA 1992, s 170(2)–(11) is to apply1.

Historically however life insurance companies have been unable

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