CFM63330 - FA2010: risk transfer schemes: summary of the legislation
Risk Transfer Schemes
The 鈥榬isk transfer scheme鈥� provisions are at CTA10/S937A to S937O.
The effect of the legislation is that where a company is party to a risk transfer scheme, certain losses are 鈥榬ing-fenced鈥� for tax purposes and can only be relieved to the extent that there are profits from the same risk transfer scheme.
The key elements of the legislation are:
- CTA10/S937C - the identification of a 鈥榬isk transfer scheme鈥� (CFM63340 and CFM63350)
- CTA10/S937E - the identification of 鈥榮cheme profits鈥� and 鈥榮cheme losses鈥� (CFM63360)
- CTA10/S937F - the identification of 鈥榬ing-fenced scheme losses鈥� and 鈥榬elevant scheme profits鈥� (CFM63370 and CFM63380)
- CTA10/S937G to S937I - the treatment of 鈥榬ing-fenced scheme losses鈥� (CFM63390 to CFM63420)