There is no need for special rules in the case of transfers of insurance business between companies that are not members of the same group. In such circumstances the parties will be taxed by reference to the profit or loss on the transfer that appears in their statutory accounts in the same way as for any commercial transaction between unconnected parties.
When considering whether parties to an insurance business transfer are members of the same group, the definition in TCGA 1992, s 170(2)–(11) is to apply1.
Historically however life insurance companies have been unable to benefit for relief for the cost of the present value of in-force business acquired under such a transfer. This asset is not subject to the intangible fixed asset rules in CTA 2009, Pt 8
To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to Tolley+™ Research or register for a free trial
Web page updated on 17 Mar 2025 17:01