Schedule 19AB to the Income and Corporation Taxes Act 1988 provides that insurance companies carrying on pension business shall be entitled to provisional repayments of tax on pension business investment income. However, during a transitional period, the Commissioners of Inland Revenue may make provision, by regulations, for the amount of a provisional repayment to be reduced by a prescribed percentage for any accounting period ending during that transitional period. The regulations may prescribe different percentages for accounting periods ending after different dates.

The Insurance Companies (Pensions Business) (Transitional Provisions) Regulations 1992 (S. I.1992/2326) (“the principal Regulations”) made provision for the transitional period to apply to accounting periods ending after 2nd October 1992 and before 1st January 1999, and prescribed 7.5 per cent. as the percentage by which the amount of a provisional repayment should be reduced during the transitional period.

The Insurance Companies (Pension Business) (Transitional Provisions) (Amendment) Regulations 1993 (S. I.1993/3109) amended the principal Regulations by prescribing 7.5 per cent. as the percentage by which the amount of a provisional repayment should be reduced for an accounting period ending after 2nd October 1992 and before 1st January 1994, and 12.5 per cent. in any other case.

These Regulations further amend the principal Regulations by prescribing 12.5 per cent. as the appropriate percentage for an accounting period ending after 31st December 1993 and before 1st January 1995, and 10 per cent. for an accounting period ending after 31st December 1994.