Commentary

D7.5171 Anti-avoidance rule – part of business transfer scheme conferring transferor life assurance trade profits advantage

Corporate tax
Corporate tax | Commentary

D7.5171 Anti-avoidance rule – part of business transfer scheme conferring transferor life assurance trade profits advantage

Corporate tax | Commentary

D7.5171 Anti-avoidance rule – part of business transfer scheme conferring transferor 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.

A life assurance trade profits advantage accrues to the transferor if its profits (losses) are less (greater) than they would have been, or were expected to have been, in the absence of any part of the scheme and any relevant associated operations1. There is however a netting mechanism that recognises that an advantage arising on part of

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