[The appeal against this decision is reported at [2006] BTC 713.]

J F Avery Jones and N Brice

Decision released

Double taxation relief – whether where the foreign income is taxed on a gross basis but forms an item of income in a Case I computation in the UK, double taxation relief is available against the whole of the UK tax on the Case I profit, or whether it is restricted to the UK tax based on a mini-Case I computation restricted to the foreign income – the former

Insurance company taxation – whether double taxation relief is calculated on the whole of the life assurance business or separately on the pension business part of the life assurance business – the latter