LAM03430 | Calculation of ‘I’ Income and chargeable gains: Unrelieved General Annuity Business (GAB) losses

Under FA1991/SCH7/PARA17 BLAGAB chargeable gains may be reduced by former GAB Case VI losses. The legislation specifies the ‘relevant part’ of the companies chargeable gains against which GAB losses can be offset by reference to the mean of opening and closing liabilities on ‘old annuity contracts’. GAB losses do not arise under the current life tax regime and hence consideration of brought forward balances in the few cases where these may still exist is all that is required.