Commentary

D7.506 Historical background – The Crown Option abolished

Corporate tax
Corporate tax | Commentary

D7.506 Historical background – The Crown Option abolished

Corporate tax | Commentary

D7.506 Historical background – The Crown Option abolished

The rules in this division apply for accounting periods beginning before 1 January 2013. For accounting periods beginning on or after 1 January 2013 see Division D7.4.

The uncertainty as to when the Crown Option might be exercised led the industry to ask that the taxation basis for life insurance companies be put on a firm statutory footing. FA 2007 therefore contained provisions to put into statute the previous position based on judicial precedent and past practice1.

FA 2007 introduced two new sections to ICTA 1988, the first providing the basis of taxation for

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