GIM7310 - Equalisation reserves: the tax rules: insurers not regulated in the UK: controlled foreign companies

Regulation 8A and 8B apply Regulation 8 to controlled foreign companies (“CFCs”) - see GIM11160. A captive insurance company therefore obtains the benefit of an equalisation reserve deduction if it maintains an equalisation reserve which is ‘equivalent’ to a reserve maintained under the Equalisation Reserves Rules. Again, the special rules which apply to credit insurance business ( GIM7120), mutual business ( GIM7260), non-annual accounts ( GIM7220) and waiver of equalisation reserves deductions ( GIM7250) all apply to equivalent reserves maintained by captive insurance companies.