The Insurance Companies (Amendment to Section 129 of, and Schedule 17 to, the Finance Act 2012) Regulations 2015
Proposed changes to the tax rules for intra-group transfers of long-term life insurance business to provide for certainty of treatment and a more commercial method in calculating the transferor's unrelieved receipts or expenses that pass to the transferee following a part transfer.
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The consultation will be of interest to life insurance companies.
Finance Act 2012 introduced new rules for taxing life insurance companies. This was a fundamental rewrite of life insurance company taxation, making the regime much more closely aligned to commercial practice. Industry has advised HM Revenue and Customs (HMRC) of some minor amendments that are required to the rules for intra-group transfers of business to ensure they work as intended.
HMRC has published draft regulations, together with a draft explanatory memorandum, which aim to address these issues. These will be subject to a period of technical consultation which will close on 11 September 2015.
We are interested to receive views on the draft regulations’ ability to provide certainty of tax treatment for intra-group transfers of long-term business and a more commercial method for calculating the transferor’s unrelieved receipts or expenses that pass to the transferee following a part transfer.
Any comments on this draft should be sent by email to darryl.wall@hmrc.gsi.gov.uk. HMRC is willing to meet interested parties directly to discuss the draft regulations. Please contact Darryl Wall by telephone on 03000 585977 or email to make arrangements as soon as possible.