Taxation of Chargeable Gains Act 1992 section 211B

Transfers of assets to certain collective investment schemes

Section 211B provides a no gain/no loss treatment when an insurance company transfers an asset into a tax-transparent collective investment scheme in exchange for units, provided the asset remains within the same long-term business category.

• When an insurance company transfers an asset into an authorised co-ownership scheme or a transparent offshore fund wholly in exchange for units, the transfer is treated as taking place on a no gain/no loss basis for corporation tax on chargeable gains purposes.
• The relief only applies if, immediately before the transfer, the asset was held for the purposes of the company's long-term business within a particular long-term business category, and immediately afterwards the units received are held within the same category.
• The long-term business categories are those set out in the Finance Act 2012: section 116 for UK life insurance companies and section 117 for overseas life insurance companies.
• A "relevant offshore fund" means an offshore fund that qualifies as a transparent fund under the Offshore Funds (Tax) Regulations 2009.