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I-E Taxation

P

PhamThinhLe

Member
In page 17, chapter 7, it is mentioned that the policyholder's share "is ring-fenced so that shareholder losses of the company or group cannot be set against it". How exactly does this interact with the minimum profits test biting where the entire I-E profit becomes shareholder's share?
 
PhamThinhLe said:
In page 17, chapter 7, it is mentioned that the policyholder's share "is ring-fenced so that shareholder losses of the company or group cannot be set against it". How exactly does this interact with the minimum profits test biting where the entire I-E profit becomes shareholder's share?
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Hi
As the CR implies this ring-fencing only applies where the whole of I-E is p/h share and so the minimum profit does not bite.
 
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