Commentary

D7.5164 Taxing the transferor – Profits and losses arising in the transferor

Corporate tax
Corporate tax | Commentary

D7.5164 Taxing the transferor – Profits and losses arising in the transferor

Corporate tax | Commentary

D7.5164 Taxing the transferor – Profits and losses arising in the transferor

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.

On a transfer of insurance business the transfer of mathematical reserves will broadly be matched by a near equal transfer of assets. While there is little doubt that the release or assumption of policy holder liabilities is on trading account, the position for assets is less clear. This is true even though the assets of a life insurance company may be viewed as akin to trading stock within CTA 2009, s 161. The legislation

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