The Impact of Income Tax on Life Assurance and Annuity Business

Extract

The original intention of this paper was to discuss the impact of income tax on annuity business only. In practice it was found impossible to discuss the impact on annuity business without at the same time discussing the impact on Life assurance business. A company transacting Ordinary life assurance, Pension annuity and General annuity business is not assessable in respect of three separate businesses; for the purpose of income tax the company conducts only one business, i.e. ‘Life Assurance and Annuity business’. Attention is drawn to this point at the outset because it is considered most important. A student coming freshly to the subject should not be misled into thinking that separate taxable units are involved because in the Income Tax Act, 1952 and the Finance Act, 1956 such terms as ‘annuity fund’ and ‘profits arising to an assurance company from pension annuity business’ are used. It may be noted that in this paper the term ‘fund’ has been avoided wherever possible, because, without precise definition on each occasion that it is used, it is liable to be misleading. It would be impracticable to discuss in one paper all the problems of a composite company which writes all classes of insurance business both at home and overseas. It is, therefore, proposed to consider only the position of a proprietary company which writes Ordinary life assurance and annuity business in the United Kingdom, values its liabilities annually and is taxed on an interest less expenses basis.