Commentary

D7.5167 Anti-avoidance rule – whole business transfer scheme conferring life assurance trade profits advantage

Corporate tax
Corporate tax | Commentary

D7.5167 Anti-avoidance rule – whole business transfer scheme conferring life assurance trade profits advantage

Corporate tax | Commentary

D7.5167 Anti-avoidance rule – whole business transfer scheme conferring life assurance trade profits advantage

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 first aspect of the TAAR applies in the case of a transfer in which the whole transfer scheme and any relevant associated operations give rise to a life assurance trade profits advantage and the sole or main benefit of the whole scheme was to obtain that advantage1. Relevant associated operations are defined as:

  1.  

    (a)     any other insurance business

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