Court of Appeal.

Judgment delivered 12 June 1986.

Corporation tax – Overseas life assurance company – Charge on investment income – Charge on profits from pension and annuity business – Method of taxation of branch or agency in UK – Legislation providing for charge on proportionate basis – Double taxation treaties providing for charge as if independent enterprise – Whether legislation overridden by or preserved by treaties – Whether proposals made through offices outside UK were made at or through UK branch – Income Tax Act 1952, sec. 430; Income and Corporation Taxes Act 1970, sec. 316.

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