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Key people

10 May 2011 / Rob Durrant-Walker
Issue: 4303 / Categories: Comment & Analysis , Business , Income Tax

Is the tax treatment of insurance for leading employees as clear cut as we think? ROB DURRANT-WALKER reviews the rules


  • 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...

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