Recognised accounts

HMRC and the appellant company could not agree on the interpretation of FA 1989, s 83A in relation to the preparation of revenue accounts by a life assurance company.

The tribunal reviewed the evidence in detail and held that the revenue accounts which were ‘recognised’ for the purposes of FA 1989, s 83A(2) were the following accounts:

• the whole of the long-term business;
   
• the life and annuity business;
   
• the permanent health insurance business; and
   
• the capital redemption business.

However, memorandum form 40 in respect of the with-profits part of the life and annuity business was not a recognised account.

The taxpayer company’s appeal was allowed.

Issue: 4227 / Categories: Tax cases , Companies