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.