Chancery Division.

Sir Richard Scott V-C.

Judgment delivered 10 May 2000.

Corporation tax – Life assurance and pension business – Repayment of tax credit – Distribution element in proceeds of sale of buy-back of shares by electricity or water utility – Whether life assurance companies entitled to tax credits – Whether a life assurance company was ‘a dealer in relation to shares’ – Whether price received for utility shares to be taken into account in computing profits under Sch. D, Case I – Income and Corporation Taxes Act 1988, s. 95(1), (2); Finance Act 1989, s. 83.

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