Section 23(p) of ITA

(p)      the value in respect of any cession of a policy of insurance ceded by a taxpayer to-

 

(i)      any-

 

(aa)    employee (or former employee);

 

(bb)   director (or former director); or

 

(cc)    dependant or nominee of the employee (or former employee) or director (or former director),

 

of the taxpayer; or

 

(ii)     any pension fund, pension preservation fund, provident fund, provident preservation fund or retirement annuity fund for the benefit of any-

 

(aa)    employee (or former employee);

 

(bb)   director (or former director); or

 

(cc)    dependant or nominee of the employee (or former employee) or director (or former director),

 

of the taxpayer;