DEFINITION OF CAPITAL
An investment by a UK individual into a policy with a Luxembourg based insurance company written in trust under which the investor was entitled to receive a 10% “income” from the encashment of units with the balance of the fund being available to the trustees after his death, was not to be treated as an overseas annuity for taxation purposes but taxed under the 5% part surrender rules that apply to life policies and capital redemption policies.
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