Commentary

D7.5166 Anti-avoidance rule

Corporate tax
Corporate tax | Commentary

D7.5166 Anti-avoidance rule

Corporate tax | Commentary

D7.5166 Anti-avoidance rule

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.

In order to protect the Exchequer from tax planning involving transfers of insurance business the government introduced a targeted anti-avoidance rule ('TAAR') in part reflecting the fact that many of the past changes to the legislation dealing with insurance business transfer schemes have been in reaction to transactions that HMRC have seen as abusive1.

The TAAR applies when an insurance business transfer scheme gives rise to a life assurance trade profits

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