[The appeal against this decision is reported at [1996] BTC 375.]

DECISION

A. Introduction

1. I have before me for decision in principle an appeal by the Prudential Assurance Company Limited (the Appellant) against an estimated assessment to corporation tax in the sum of £200m made in respect of its Life Fund for the calendar year 1989. In making that assessment the Inspector relied on the provisions of section 76 of the Income and Corporation Taxes Act 1988 (‘ICTA 1988’) which applies, with modifications, the provisions of section 75 (relating to investment companies) to the computation of profits of a life company carrying on the business of life assurance.

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