If the assets held by an insurance company for the purposes of its long-term business include holdings in certain collective investment vehicles, the company is deemed, for the purposes of corporation tax on capital gains, to have disposed of and immediately re-acquired them at their market value at the end of each ac-counting period. The holdings concerned are rights in an authorised unit trust, interests in an offshore fund, units in an authorised contractual scheme which is a co-ownership scheme, shares in a company to which the Real Estate Investment Trust rules in CTA 2010, ss 518–609 (Pt 12) apply and shares in a company to which the Qualifying Asset Holding Company rules in FA 2022, Sch 2 apply (collectively 'section 212 assets')1. These rules do not apply to such assets if they are subject to tax as loan relationships under CTA 2009, Pt 6 Ch 3.
The aim of the legislation is to tax or allow, as capital gains or capital losses, the increases and decreases in the value
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