129 Intra-group transfers and demutualisation

129  Intra-group transfers and demutualisation

(1)     This section applies if—

(a)     under an insurance business transfer scheme, there is a transfer of basic life assurance and general annuity business (or any part of that business) from one insurance company to another, and

(b)     the transfer is a relevant intra-group transfer or is in connection with a demutualisation.

(2)     A transfer is a “relevant intra-group transfer” if—

(a)     the transferor and transferee are members of the same group of companies when the transfer occurs, and

(b)     the transferee is within the charge to corporation tax in relation to the transfer.

(3)     A transfer is “in connection with a demutualisation” if—

(a)     it is for the purposes of the conversion of a company (under the law of any territory) from one without share capital to one with share capital (without any change of legal personality), or

(b)     it is a transfer by a mutual life insurance company of all, or substantially all,

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