Corporation Tax Act 2009 section 904

Transfers of life assurance business: transfers of assets treated as tax-neutral

Section 904 provides for the tax-neutral transfer of intangible fixed assets when those assets form part of certain transfers of life assurance business between insurance companies.

• When life assurance business is transferred between insurance companies, any intangible fixed assets included in that transfer may qualify for tax-neutral treatment under this section.
• Tax-neutral treatment means the transferring company is not treated as making a taxable gain or loss on the assets at the point of transfer.
• The receiving company effectively steps into the shoes of the transferring company, inheriting the same tax history for those intangible fixed assets.
• This provision sits within the broader intangible fixed assets regime and ensures that legitimate business transfers of life assurance portfolios are not impeded by unexpected tax charges on qualifying intangible assets.