Commentary

D7.491 Effect of the modified rules

Corporate tax
Corporate tax | Commentary

D7.491 Effect of the modified rules

Corporate tax | Commentary

D7.491 Effect of the modified rules

If the modified rules apply there are potentially three conditions which may remove either the principal CFC or any associated CFC from the operation of the wider CFC rules.

  1.  

    (a)     The CFC rules will apply only if the insurance company controls the principal CFC by reference to accounting standards1. Therefore only those CFCs that are consolidated into the insurance company's statutory accounts may be CFCs. This relaxation reflects the difficulty of establishing ownership structures in diversely held tiered fund investments.

  2.  

    (b)     The CFC rules will not apply to an insurance company's investment in the

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