Life Assurance Premium Relief. Reg. 10(6), Income Tax (LAPR) Regulations 1978.Under this system of relief, withdrawn on 13 March 1984, individual policyholders deducted income tax from life assurance premiums paid, and the life office then recovered such amounts (‚Äö√Ñ√∫the deficiencies‚Äö√Ñ√π) from the Inland Revenue. In this case there was a substantive issue concerning whether certain policies were written before of after 13 March 1984 – deficiencies had been recovered in respect of such policies between 1984 and 1991, and the Inland Revenue now claimed that overpayments of relief had been made. The Inland Revenue was out of time to raise an assessment for such overpayments. A preminary question for determination, raised by originating summons, was whether regulation 10(6) of the 1978 Regulations permits the Inland Revenue to recover any such overpayments without raising an assessment.Held: regulation 10(6) does confer on the Inland Revenue an immediate enforceable right to recover overpayments made by it, if it succeeds on the substantive issue.David Goy KC and Philip Baker appeared for the life office
United Friendly Insurance plc v IRC (Chancery Division)
GITC is sad to report the death of our Head of Chambers, Mr Milton Grundy who passed away at the weekend.
Gray’s Inn Tax Chambers is deeply saddened by the passing of our founding member and Head of Chambers, Mr Milton Grundy
28 Nov 2022
Gray’s Inn Tax Chambers is deeply saddened to learn of the death of Her Majesty Queen Elizabeth II.
We join the nation in mourning and our condolences are with the Royal Family.
09 Sep 2022
The 2022 GITC Review is now available
If you would like to be added to the mailing list for future issues of the GITC Review, please send an email to Jane.Fullbrook@taxbar.com.