The government has altered earlier proposals to introduce a ‘with-profits tax' on reserve funds in a move which eill leave listed life insurance companies with tax bills worth hundreds of millions of pounds.
According to notification issued by HM Revenue and Customs last week which will make up part of the draft rules for the Finance Bill 2006, two anti-avoidance measures are being introduced to stop life insurance companies from “creating artificial losses or reducing taxable profits” by listing them as assets within the investment reserves of the company. In a 12-page document entitled Life Insurance Companies: Countering Avoidance the Treasury is looking to extend proposals for a ‘with-profits tax’ to all surplus assets not directly set aside for with-profits policyholders and stop former...
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