Commentary

D7.5162 Taxing the transferor — Retained assets

Corporate tax
Corporate tax | Commentary

D7.5162 Taxing the transferor — Retained assets

Corporate tax | Commentary

D7.5162 Taxing the transferor — Retained assets

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 purpose of the retained assets provision is to prevent the transferor avoiding tax on extracting assets formerly held in the investment reserve of its long-term insurance fund by the simple expedient of retaining them until after it has ceased to write long-term business, the resulting uplift in value not being taxed because it no longer carried on long-term insurance business.

The relevant amount of any retained

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