Commentary

D7.552 Ring fencing of losses

Corporate tax
Corporate tax | Commentary

D7.552 Ring fencing of losses

Corporate tax | Commentary

D7.552 Ring fencing of losses

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.

There has always been a clear ring-fence around the income and management expenses of a life insurance company's long-term insurance fund such that the policy holders' share of the profits could not benefit from general corporate tax reliefs such as group relief and any excess management expenses were unavailable for surrender as group relief. However there was no such overt ring-fence applicable to the capital gains and losses

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