Taxation (International and Other Provisions) Act 2010 section 453

Insurance entities

Section 453 provides special rules to exclude certain portfolio investments held by insurance entities from being treated as part of the insurer's worldwide group for the purposes of the corporate interest restriction rules.

• Where an insurance entity holds a subsidiary purely as a portfolio investment, that subsidiary (and its own subsidiaries) is excluded from the insurer's worldwide group
• A portfolio investment is one held as an investment whose value is judged wholly or mainly by reference to its market value
• The excluded subsidiary is not treated as a consolidated subsidiary of any member of the insurer's group, allowing it to form its own separate worldwide group
• Insurance entities covered by this rule include insurance companies, friendly societies, and corporate members of Lloyd's