Taxation of Chargeable Gains Act 1992 Schedule 5AAA paragraph 7A

Overseas life insurance companies

Section 7A provides an exemption from the normal rules on disposals by non-UK residents for overseas life insurance companies that meet certain conditions relating to their UK property exposure and the size of their investment in the collective investment vehicle being disposed of.

  • The exemption applies to overseas life insurance companies (or entities that would qualify as such if they carried on life assurance business in the UK through a permanent establishment)
  • No more than 40% of the company's asset value, measured immediately before disposal, may derive from UK land interests or interests in UK property rich companies
  • The asset disposed of must be a right or interest in a collective investment vehicle that is a company and is UK property rich
  • The company must not hold a 10% or greater investment in the collective investment vehicle immediately before the disposal

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