Commentary

D7.490 Application of the modified rules

Corporate tax
Corporate tax | Commentary

D7.490 Application of the modified rules

Corporate tax | Commentary

D7.490 Application of the modified rules

The modified rules apply whenever an insurance company to which the I-E rules apply is deemed to make disposal of an interest in an offshore fund (see D7.444), the offshore fund in question is a CFC and there would be a CFC charge on the company arising from its interest in that offshore fund but for the application of the modified rules1.

Because the purpose of the rules is to simplify the compliance burden on insurance companies as investors in these types of vehicles, it is not necessary to look through the ownership structure of

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