IFM29100 - Real Estate Investment Trust : Miscellaneous: insurance companies holding shares in a UK-REIT: TCGA1992/S212
Background
TCGA1992/S212 applies to various kinds of assets held by a UK or overseas insurance company as part of its long term business. This includes holdings in authorised unit trusts, interests in offshore funds, units in an authorised contractual scheme which is a co-ownership scheme and shares in a UK-REIT. For the purposes of taxation of chargeable gains, the insurance company is deemed to have sold the assets and immediately reacquired them at market value at the end of each accounting period. TCGA1992/S213 then spreads the gains or losses that arise on the deemed disposals over seven years.
For more information on the taxation of long term insurance funds of life companies, see the Life Assurance Manual.