Commentary

D7.538 Reinsurance—attribution of investment return

Corporate tax
Corporate tax | Commentary

D7.538 Reinsurance—attribution of investment return

Corporate tax | Commentary

D7.538 Reinsurance—attribution of investment return

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 assessment of the profits from life reinsurance business under the life assurance trade profit provisions, whether directly in the case of a pure reinsurer1 or otherwise as part of the gross roll up category2, has the effect of excluding any investment return accruing for the benefit of policy holders from tax in the hands of the reinsurer (the investment return being balanced by an increase in the

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