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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. Calculating gains: death, maturity, full surrender or assignment: value of the policy or contract

IPTM3515 | Calculating gains: death, maturity, full surrender or assignment: value of the policy or contract

From HM Revenue & Customs · Insurance Policyholder Taxation Manual

The value of the policy or contract to be brought in under ‘total benefits’ depends on the nature of the chargeable event.

Surrender of all rights, maturity

The value of the policy or contract is

  • any sum payable because of the event

  • in the case of a life insurance or capital redemption policy:

- if a right to periodical payments arises because of the event, an amount equal to the capital value of those payment at the time the right arises

- the amount or value of any other benefits arising because of the event.

An ‘income payment’ under a guaranteed income bond contract is treated as a full surrender if it is the final benefit under the contract - see IPTM3550.

Events under annuity contracts treated as a surrender of all rights

The approach under the previous heading also applies to:

  • death under a life annuity contract made on or after 10 December 1974 providing for a capital sum on death

  • taking a capital sum as a complete alternative to annuity payments, or further annuity payments, under a life annuity.

Assignment of all rights

The value of the policy or contract is the amount or value of the assignment consideration, unless the assignment is of a life policy or annuity between connected persons. In that case the market value is substituted, unless there was no consideration so the assignment was not a chargeable event - see IPTM3400. The meaning of connected persons is given by the definition in ICTA88/S839 and S994 for income tax, and CTA10/S1122 and S1123 for corporation tax. See CG14580 onwards, which refers to the similar connected persons definition at TCGA92/S286.

Death

The value of the policy is its surrender value immediately before death. This has the effect of confining the gain to investment growth and excluding the life risk element.

Disregarded amounts

There are some amounts disregarded under these rules

  • ‘retained replacement policy premiums’, see IPTM3520

  • trivial inducement benefits, see IPTM3535.

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