Suggestion on Corporate Streaming

At the risk of overdoing posts on corporate streaming there was one suggestion that I have for a revised approach that I think might work.

HMRC seems to have three aims from abolishing streaming.  Firstly it eliminates complexity, secondly it reforms rules that have at times been used in various tax avoidance schemes and finally abolishing streaming prevents the reclaim or repayment of tax where no tax has been paid in the AIF concerned.(see paragraphs 13.15 - 13.18 of the con doc).

Life insurance companies with pension business want to keep streaming as it allows them to use AIFs for pension business investment without the investors suffering an inappropriate tax charge.

I wonder if you could secure all four objectives by abolishing corporate streaming but retain the concept of the net liability to corporation tax and allow that net liability to be repaid when the dividend concerned is referable to the pension business of a life insurance company?

I'm not claiming it's as good a solution as retaining corporate streaming but it gives HMRC the win of abolishing streaming, explicitly links repayment to tax actually paid at the AIF level and retains the concept that arbitrary tax charges shouldn't be applied to pension business policyholders.

Also if the repayment of the net liability to corporate tax to life insurers was accepted it would then be possible to lobby for its extension to pension funds, charities etc.