HC Deb 14 April 1930 vol 237 cc2688-9



  1. (a) in computing for the purposes of Sur-tax the total income for any year of 2689 an individual who has entered into a contract of assurance or into a contract similar in character to a contract of assurance, being in either case a contract under which a capital sum is expressed to be payable in the future in return for one or more antecedent payments, no deduction shall (subject to such exceptions and qualifications as Parliament may by any Act of the present Session relating to Finance determine) be allowed in respect of any interest on, or other sum payable in respect of, any borrowed money which has been applied directly or indirectly to or towards the making of any of the antecedent payments or of any payment made in lieu of any of those payments, or to or towards the replacement of any money so applied; and
  2. (b) where the benefit of any such contract as aforesaid entered into by any person has become vested in another person being an individual, paragraph (a) of this Resolution shall apply in relation to that individual—
    1. (i) as if the contract had been a contract entered into by him; and
    2. (ii) in a case where the benefit became vested in him by virtue of an assignment and any payment was made by him in consideration of the assignment, as if that payment were an antecedent payment under the contract; and
    3. (iii) in a case where, either as being the person in whom the benefit is vested or by reason of any agreement under or in pursuance of which the benefit became vested in him, he pays any interest on or makes any other payment in respect of any borrowed money, as if that money had been applied towards the making of an antecedent payment under the contract."