Commentary

D7.5180 Losses and other reliefs

Corporate tax
Corporate tax | Commentary

D7.5180 Losses and other reliefs

Corporate tax | Commentary

D7.5180 Losses and other reliefs

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.

As the tax rules attempt to follow the general principle that the transferee stands in the shoes of the transferor in all regards with respect to the transferred business, relief is also available to the transferee for management expenses, losses and other allowances following an insurance business transfer scheme1.

Any unrelieved expenses of management of the transferor company are taken over by the transferee company subject to the special rules for spreading BLAGAB acquisition expenses (see D7.565)2. Any unused Schedule D Case VI losses attributable to transferred gross roll up business (pension business, overseas life assurance business, life reinsurance business or ISA business

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to TolleyLibrary or register for a free trial