Commentary

D7.518 Loan relationships

Corporate tax
Corporate tax | Commentary

D7.518 Loan relationships

Corporate tax | Commentary

Group issues

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.

Life insurance companies will typically be members of groups of companies either as ultimate parent or more normally as subsidiaries. Many of the tax rules affecting groups apply equally to life insurance companies although they recognise the fact that the income and gains accrue for the benefit of the policy holders as well as the shareholders. This is particularly true of assets of the long-term insurance fund which are

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