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 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 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

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