Resolution, the vehicle of Clive Cowdery, the insurance tycoon, denied yesterday that its stock market float would be derailed by a planned Treasury review of offshore financial centres.

Resolution announced plans last week to raise £1 billion from investors. The Guernsey-registered company will seek to buy businesses in the life, general insurance, fund management and banking sectors.

However, Alistair Darling’s statement with his PreBudget Report on Monday suggested that the Treasury was considering a clamp-down on locations such as Guernsey, the Isle of Man and Gibraltar. Promising a “review of regulatory arrangements”, the Chancellor told MPs: “Recent financial turbulence has highlighted potential problems with overseas territories and Crown dependencies, such as the Isle of Man and the Channel Islands. They attract banking customers with lower taxes – without contributing to the UK Exchequer.”

This prompted Andy Hughes, the respected insurance analyst for JPMorgan Securities, to publish a note to clients on Monday night suggesting that the float could be delayed. He wrote: “The review adds a layer of uncertainty to the future tax status and attractiveness of Guernsey as a domicile.”

Resolution insisted that the review would apply only to savings business, rather than insurance, in which corporate tax rates are set by Guernsey and not by the Treasury. A spokesman said: “We don’t believe the review will impact capital gains tax, so we haven’t considered moving domicile.” It is understood that, if the Treasury review did affect its tax status, Resolution would look to move domicile. Mr Hughes yesterday issued a note clarifying the position, but said that the study “could easily broaden” and that costs of a domicile move were unclear.

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