Explanatory note

These Regulations make provision for the taxation of qualifying transformer vehicles.

Regulation 1 provides for citation, commencement and effect.

Regulation 2 defines terms used in the Regulations.

Regulation 3 sets out the conditions for constituting a qualifying transformer vehicle.

Regulation 4 provides for an exemption for corporation tax.

Regulation 5 removes the income tax withholding obligation.

Regulations 6 to 8 sets out circumstances where the special tax treatment will be removed, regulation 7 relates to penalties and regulation 8 applies where the purpose of the risk transformation is to secure a tax advantage.

Regulations 9 to 11 make provision in relation to the application of the Corporation Tax Acts.

A Tax Information and Impact Note covering this instrument was published on 23 November 2016 alongside the draft Risk Transformation (Tax) Regulations 2017 and is available on the website at https://www.gov.uk/government/publications/tax-regime-for-insurance-linked-securities/tax-regime-for-insurance-linked-securities. It remains an accurate summary of the impacts that apply to this instrument.