This study examines the difficult task of applying income taxation to the life and property and casualty insurance industries. Particularly in the case of life insurance, OECD countries have pursued a variety of methods to try to tax the income arising in insurance companies. This study analyses the policy and technical problems that arise in designing an effective means of income taxation. In addition to outlining the general approaches used by OECD countries in this area, the authors have drawn upon their extensive practical experience in designing a tax system for the insurance industry in their home country. Based on this experience, they have addressed the major policy questions faced by tax policy-makers in this area and included a critical analysis of the various technical issues which arise in turning theory into practice.