The question arising was whether paragraph 55(2) of Schedule 8 to the Finance Act 1995, a reinsurance treaty entered into on 25 November 1994 by the taxpayer reinsurer with a non-resident cedant is, by virtue of the fact that policies of life assurance ceded by that treaty were issued before 1 November 1994, within the … Continue reading Barrett (HM Inspector of Taxes) v Royal London Mutual Insurance Society Ltd: CA 12 Jun 2003

Paragraph 57(2) of Schedule 8 to the Finance Act 1995, which provides that section 442A of the Taxes Act 1998 ‘does not apply in relation to the reinsurance of a policy or contract where the policy or contract was made, and the reinsurance arrangement effected, before 29 November 1994’, provided an indication that the opening … Continue reading Barrett (HM Inspector of Taxes) v Royal London Mutual Insurance Society Ltd: ChD 5 Jul 2002