Source: All England Reporter
Publisher Citation: [2001] All ER (D) 138 (Nov)
Court: Court of Appeal, Civil Division
Judge:

Pill, Robert Walker LJJ and Laddie J

Representation Leolin Price QC and Evan Price (instructed by Jeffrey Green Russell) for the applicant.
  Timothy Brennan QC (instructed by the Solicitor of Inland Revenue) for the commissioners.
Judgment Dates: 9 November 2001

Catchwords

Income tax - Charge to tax - Liability - Insurance - Life policy - Qualifying policy - Proceeds of qualifying policy not chargeable to tax - Revenue declining to certify draft policy as qualifying policy - Whether draft policy meeting statutory test for qualifying policy - Whether Revenue having discretion to refuse to certify policy which meets statutory requirements -  15, paras 1, 21.

The Case

The form of a draft life policy submitted for certification by the Revenue as a qualifying policy did not meet the statutory test in Pt I of Sch 15 to the .

Practice Areas

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