87U.K.After section 213 insert—
“213APower to modify ss.212 and 213 etc in case of CFCs that are offshore funds
(1)The Treasury may make regulations for the purpose mentioned in subsection (2) in any case where—
(a)an insurance company to which the I - E rules apply is deemed to make a disposal under section 212 of an interest in an offshore fund,
(b)the offshore fund is a CFC, and
(c)there is (or, but for the regulations, would be) a CFC charge on the insurance company referable to its relevant interest in the CFC for the accounting period in which the disposal is deemed to have been made.
(2)The regulations are to be made for the purpose of modifying the operation of—
(a)section 212 or 213,
(b)the CFC rules, or
(c)the I - E rules,
in relation to any accounting period of the insurance company so as to reduce the charge to tax.
(3)The regulations may—
(a)make different provision for different cases or circumstances, and
(b)contain incidental, supplementary, consequential, transitional, transitory or saving provision.
(4)The provision that may be made as a result of subsection (3)(b) includes provision modifying any other provision of the Corporation Tax Acts.
(5)In this section—
“CFC” and “CFC charge” have the same meanings as in Part 9A of TIOPA 2010 (see section 371VA),
“the CFC rules” means the rules contained in that Part, and
“offshore fund” has the meaning given by section 355 of TIOPA 2010.”