Commentary

D7.428 Indexed-linked gilts

Corporate tax
Corporate tax | Commentary

D7.428 Indexed-linked gilts

Corporate tax | Commentary

D7.428 Indexed-linked gilts

Under the rules that applied until 31 December 2012 the loan relationship rules had no application in calculating the measure of trade profits from life assurance business. Following the move to an accounts based method of calculating trade profits it was decided that there was no longer any policy reason to exempt life insurers from the loan relationship rules which themselves are accounts based. Nevertheless life insurance companies are significant holders of indexed linked gilt-edged securities which are often used to back pension annuities in payment. Allowing the investment return on such securities to escape tax as

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