213A(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.

213A(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,

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