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HMRC v Legal & General Assurance Society Ltd (No 2)

In HMRC v Legal & General Assurance Society Ltd (No 2) (Upper Tribunal – 12 October) HMRC began an enquiry into the returns submitted by a large life insurance company. HMRC and the company were unable to agree on which of the company’s revenue accounts were ‘required to be prepared’ for the purposes of FA 1989 s 83A(2)b). They referred the dispute to the Special Commissioners under FA 1998 Sch 18 para 31A. The case was heard by the First-Tier Tribunal (which had succeeded the Special Commissioners following the implementation of the Tribunals Courts and Enforcement Act 2007 with effect from 1 April 2009). The Tribunal reviewed the evidence in detail and found in favour of the company holding that the revenue accounts which were ‘recognised’ for the purposes of s 83A(2) were ‘the revenue account in respect of the whole of the long term business; the...

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