ÑÇÖÞÉ«ÇéÍø

Home / Simons-Taxes /Corporate tax /Part D7 Financial service sectors /Division D7.4 Life insurance and friendly societies etc /Overview of and general principles of taxation of long-term insurance business / D7.404 Long-term business—background to taxation principles and administration
Commentary

D7.404 Long-term business—background to taxation principles and administration

Corporate tax

Insurance business is a trade for taxation purposes1, and the Corporation Tax Acts therefore apply to an insurance company in the same way as they apply to any other trading company, except where the law has been modified by special provisions applicable to insurance companies only.

A study of the life assurance provisions of the Corporation Tax Acts, however, is not in itself enough to give an understanding of how life insurance companies are taxed. At the end of the 19th and the beginning of the 20th centuries, a number of important disputes between life insurance companies and HMRC reached the courts. Among these were Clerical, Medical and General Life Assurance Society v Carter2, in which the Court of Appeal upheld the Crown's right to tax interest

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to Tolley+™ Research or register for a free trial

Web page updated on 17 Mar 2025 16:24