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Contents

Official guidance
Insurance Policyholder Taxation Manual

IPTM3000 · Chargeable events

  • IPTM3100 · The charge to tax: income tax and corporation tax
  • IPTM3110 · The charge to tax: income tax
  • IPTM3120 · The charge to tax: corporation tax
  • IPTM3130 · The charge to tax: corporation tax: points of difference
  • IPTM3200 · Person liable to charge
  • IPTM3210 · Person liable to charge: chargeable event certificates
  • IPTM3220 · Person liable to charge: individuals and companies
  • IPTM3230 · Person liable to charge: UK resident trustees
  • IPTM3240 · Person liable to charge: death cases
  • IPTM3250 · Person liable to charge: summary of the position in relation to trusts
  • IPTM3260 · Person liable to charge: non-UK resident trustees and foreign institutions
  • IPTM3270 · Person liable to charge: multiple interests
  • IPTM3280 · Person liable to charge: multiple interests: chargeable event certificates
  • IPTM3290 · Person chargeable: multiple interests: trusts created by more than one person
  • IPTM3300 · Policies and contracts charged: general
  • IPTM3310 · Policies and contracts charged: qualifying policies
  • IPTM3320 · Policies and contracts charged: personal portfolio bonds
  • IPTM3330 · Policies and contracts charged: ‘foreign policies’
  • IPTM3400 · When events occur: general
  • IPTM3410 · When events occur: exceptions
  • IPTM3420 · When events occur: no chargeable event
  • IPTM3430 · When events occur: disregard of certain assignments
  • IPTM3500 · Calculating gains: general
  • IPTM3505 · Calculating gains: ‘insurance year’
  • IPTM3510 · Calculating gains: death, maturity, full surrender or assignment
  • IPTM3515 · Calculating gains: death, maturity, full surrender or assignment: value of the policy or contract
  • IPTM3520 · Calculating gains: death, maturity, full surrender or assignment: replacement policies
  • IPTM3525 · Calculating gains: death, maturity, full surrender or assignment: related policies
  • IPTM3527 · Calculating gains: maturity, full surrender or assignment: commission rebated or reinvested as premium
  • IPTM3528 · Calculating gains: maturity, full surrender or assignment: commission rebated: examples
  • IPTM3530 · Calculating gains: death, maturity or full surrender: qualifying endowment policies held as security for company debts
  • IPTM3535 · Calculating gains: death, maturity or full surrender: disregard of trivial inducement benefits
  • IPTM3540 · Calculating gains: part surrenders and part assignments: ‘periodic calculations’ and ‘excess events’: general
  • IPTM3545 · Calculating gains: part surrenders and part assignments: ‘periodic calculations’ and ‘excess events’: events treated as part surrenders
  • IPTM3550 · Calculating gains: part surrenders and part assignments: ‘periodic calculations’ and ‘excess events’: guaranteed income bonds
  • IPTM3555 · Calculating gains: part surrenders and part assignments: ‘periodic calculations’ and ‘excess events’: definitions
  • IPTM3560 · Calculating gains: part surrenders and part assignments: ‘periodic calculations’ and ‘excess events’: calculation method
  • IPTM3565 · Calculating gains: part surrenders and part assignments: ‘periodic calculations’ and ‘excess events’: value of rights surrendered or assigned
  • IPTM3570 · Calculating gains: part surrenders and part assignments: ‘periodic calculations’ and ‘excess events’: special cases
  • IPTM3575 · Calculating gains: part surrenders and part assignments: ‘periodic calculations’ and ‘excess events’: assignments involving co-ownership
  • IPTM3580 · Calculating gains: part surrenders and part assignments: ‘transaction-related calculations’
  • IPTM3585 · Calculating gains: part surrenders and part assignments: ‘transaction-related calculations’: calculation method
  • IPTM3590 · Calculating gains: part surrenders and part assignments: ‘transaction-related calculations’: ‘final insurance year’: special rules
  • IPTM3595 · Calculating gains: part surrenders and part assignments: ‘transaction-related calculations’: chargeable event
  • IPTM3596 · Calculating gains - recalculating a wholly disproportionate gain under ITTOIA05/S507A and S512A
  • IPTM3597 · Calculating gains - recalculating a wholly disproportionate gain under ITTOIA05/S507A and S512A: examples
  • IPTM3600 · Personal portfolio bonds: background: ITTOIA05/S515
  • IPTM3610 · Personal portfolio bonds: meaning: bonds made on or after 17 March 1998: ITTOIA05/S516
  • IPTM3620 · Personal portfolio bonds: meaning: bonds made before 17 March 1998
  • IPTM3630 · Personal portfolio bonds: meaning: index selection: ITTOIA05/S517(1)
  • IPTM3640 · Personal portfolio bonds: meaning: property selection: ITTOIA05/S517(2)
  • IPTM3650 · Personal portfolio bonds: calculation method: ITTOIA05/S522
  • IPTM3660 · Personal portfolio bonds: calculation method: example
  • IPTM3670 · Personal portfolio bonds: chargeable event
  • IPTM3700 · Foreign policies: differences in treatment
  • IPTM3710 · Foreign policies: effect on qualifying status
  • IPTM3720 · Foreign policies: basic rate tax not treated as paid
  • IPTM3730 · Foreign policies: reduction for non-UK policyholder
  • IPTM3731 · Reduction for non-UK policyholder from 6 April 2013
  • IPTM3732 · Calculation of the reduction in gain from 6 April 2013: ITTOIA05/S528
  • IPTM3733 · Non-UK policyholder and assignments and shared rights
  • IPTM3734 · Gains arising during period of non-UK residence
  • IPTM3735 · Gains arising to personal representatives and trustees
  • IPTM3736 · Interaction between restricted relief qualifying policies and top slicing relief
  • IPTM3740 · Foreign policies: reduction for non-UK policyholder: example
  • IPTM3800 · Income tax treated as paid and reliefs
  • IPTM3810 · Income tax treated as paid
  • IPTM3820 · Top slicing relief: general
  • IPTM3830 · Top slicing relief: calculation
  • IPTM3840 · Top slicing relief: how relief is given
  • IPTM3850 · Top slicing relief: examples
  • IPTM3860 · Deficiency relief: entitlement
  • IPTM3870 · Deficiency relief: calculation of deficiency
  • IPTM3880 · Deficiency relief: calculation of deficiency relief
  • IPTM3900 · Policies and contracts owned by companies: application of the loan relationships rules: scope and commencement
  • IPTM3905 · Policies and contracts owned by companies: application of the loan relationships rules: accountancy treatment of investment life insurance contracts
  • IPTM3910 · Policies and contracts owned by companies: application of the loan relationships rules: non-trading credits and debits
  • IPTM3915 · Policies and contracts owned by companies: application of the loan relationships rules: payouts on death or critical illness
  • IPTM3920 · Policies and contracts owned by companies: application of the loan relationships rules: tax treated as paid: description of mechanism
  • IPTM3925 · Policies and contracts owned by companies: application of the loan relationships rules: tax treated as paid: examples
  • IPTM3930 · Policies and contracts owned by companies: application of the loan relationships rules: transition from chargeable events rules: deemed surrender
  • IPTM3935 · Policies and contracts owned by companies: application of the loan relationships rules: transition from chargeable events rules: contracts accounted for on fair value basis
  • IPTM3940 · Policies and contracts owned by companies: application of the loan relationships rules: transition from chargeable events rules: contracts accounted for other than on fair value
  1. Chargeable events: contents
  2. Person liable to charge: multiple interests

IPTM3270 | Person liable to charge: multiple interests

From HM Revenue & Customs · Insurance Policyholder Taxation Manual

It is quite common for more than one person to own the rights in a policy. The general rule is that each interested person is chargeable on the share of the total gain which is the same as their share in the policy rights, or share of the debt which the policy is used to secure. In most cases there is no difficulty. For example, joint interests of domestic partners are treated as equal shares and the gain is split 50-50.

In some cases different persons may hold rights of a different kind. For example, one person may hold a right to death benefit only while another may hold an additional right to critical illness benefit under the same policy. In these circumstances any gain is divided among the different persons on a just and reasonable basis and generally this will reflect the parties’ self assessments.

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