Is the tax treatment of insurance for leading employees as clear cut as we think? ROB DURRANT-WALKER reviews the rules
KEY POINTS
- The Anderson Rules and their origin.
- The case law concerning key man insurance.
- Is being a controlling shareholder important?
- HMRC’s instructions and the importance of motive.
- Determining the relevant factors for relief.
- Are you prepared to argue your case?
Sometimes we run the danger of only doing half a job when we look at a tax case in the course of work. It is too easy to read a précis that the case says so-and-so therefore the client can or can’t do what they wanted to: box ticked end of argument.
References in our tax resources or in HMRC’s manuals can come down to a few brief lines even a sentence. Often time and cost pressures of the job or materiality...