Chancery Division.

Neuberger J.

Judgment delivered 30 October 2000.

Corporation tax – Investment income – Mutual insurance business – Non-UK resident – Investment in treasury securities – Securities subject to ‘free of tax for residents abroad’ exemption – Restriction existed on exemption so interest not excluded from computation of tax in respect of profits of trade or business – Finance (No. 2) Act 1931, s. 22F – Finance Act 1940, s. 60.

Facts