3A(1)  This regulation applies for the purposes of regulation 2 where there has been a substantial change in the long-term business of a company.

3A(2)  Where the change occurred or occurs on or before 31st December 2010–

(a)in the first period of account ending on or after 31st December 2010 the basis of deduction is either–

(i)the basis specified in regulation 3; or

(ii)such other basis to determine the amount of tax expended on behalf of policy holders or annuitants as is just and reasonable; and

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