FTT decides on meaning of “structural asset” in the taxation of insurance companies

”The FTT has allowed the appeal of Guardian Assurance in relation to the taxation of life business and, specifically, the tax treatment of an investment in a Canadian life insurer. The FTT addressed the meaning of “structural asset” for the purposes of an insurer’s “long term business fixed capital”.

Jonathan Peacock QC and Michael Ripley acted for Guardian Assurance

The Judgement can be found here.”