Commentary

D7.489 Modified CFC rules for insurance companies

Corporate tax
Corporate tax | Commentary

D7.489 Modified CFC rules for insurance companies

Corporate tax | Commentary

Controlled foreign companies

D7.489 Modified CFC rules for insurance companies

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.

The changes to the controlled foreign companies regime effective from 1 January 20131 highlighted a number of issues for insurance companies that hold investments in overseas companies that may be CFCs. In particular when such companies hold these investments on behalf of their policyholders there is likely to be little risk that tax will escape charge. In the first instance annual movements in

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