Commentary

D7.551 Transfers between companies

Corporate tax
Corporate tax | Commentary

D7.551 Transfers between companies

Corporate tax | Commentary

D7.551 Transfers between companies

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 noted in D7.550, ICTA 1988, s 440 disapplies the general no gain/no loss rules for transfers between companies in the same group and in doing so creates a ring-fence around assets of a life insurer's long-term insurance fund. Any acquisition (or disposal) of an asset within one of the categories (a) to (c) in TA 1988 s 440(4) from (or to) a fellow group company will therefore follow

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