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The taxpayer company said that as a basic life assurance and general annuity business it was entitled to deduct unused losses in reaching its Schedule D Case I profit for the purposes of FA 1989 s 89.
The Special Commissioner held that for accounting periods which began before 1 January 2003 TA 1988 s 393 reduced the profits of a particular period by brought forward losses of prior years for the purposes of FA 1989 s 89.
However subsequent amendments to s 89 meant that only post-2003 losses could be brought forward in respect of accounting periods which began after 1 January 2003.
The taxpayer appealed and HMRC cross-appealed.
The High Court judge said that TA 1988 s 393 did not apply to Case I. Rather it was a corporation tax provision in the form of a relief which fell to...
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