Questione giuridica chiave
Whether surplus amounts used to finance a lifelong annuity increase constitute an insurance premium subject to stamp duty.
Decisione estratta
No. The surplus-funded annuity increase was part of the original contractual performance and did not amount to a new premium payment.
Motivazione estratta
The policy already granted the insured a conditional right to a higher annuity if surplus arose. The insured paid the original premium for the combined minimum and conditional surplus-linked benefit. Treating the surplus as a new premium would lead to double taxation and ignore the contract's unified structure.