The assets included in the transfer include intangible fixed assets that are chargeable intangible assets for the respective companies immediately before and after the transfer. (In view of the fact that most life assurance intangible fixed assets are not chargeable ( CIRD25115), this provision may have limited effect).
Paragraph 89 defines:
‘Contracts of long term insurance’ as contracts that fall within Part 2 of Schedule 1 of SI2001/54.
‘Insurance business transfer scheme’ means a scheme within section 105 of the Financial Services and Markets Act 2000, or an excluded scheme falling within Case 2, 3, or 4 of subsection (3) of that section.
Further information on the taxation of life assurance companies is available from the Revenue Life Assurance Manual (LAM).