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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. Personal portfolio bonds: meaning: property selection: ITTOIA05/S517(2)

IPTM3640 | Personal portfolio bonds: meaning: property selection: ITTOIA05/S517(2)

From HM Revenue & Customs · Insurance Policyholder Taxation Manual

A policy or contract is not a personal portfolio bond (PPB) merely because its terms permit the selection of property as described at IPTM3610 if all of the property which may be selected:

  • falls within the following property categories (ITTOIA05/S520):

  1. property appropriated by the insurer to an internal linked fund (IPTM7740)

  2. units in an authorised unit trust, see ( IFM02120)

  3. shares in an investment trust, see (IFM14120) onwards, or an overseas equivalent (IPTM7750)

  4. shares in an open-ended investment company, see ( IFM02130)

  5. cash (IPTM7755)

  6. a life policy, life annuity or capital redemption policy, unless excluded (see below)

  7. specified interests in collective investment schemes (see below)

  8. shares in a UK Real Estate Investment Trust (REIT) or an overseas equivalent (IFM22016)

  9. an interest in an authorised contractual scheme, and

  • meets either the general or class property selection conditions (ITTOIA05/S521):

general condition: property meets this condition if, at the time when it may be selected, the opportunity to select property falling within the same category is available to:

- all policyholders of the insurer, or

- persons acting on behalf of those policyholders

class condition: property meets this condition if, at the time when it may be selected, the opportunity to select property falling within the same category is available to:

- a particular class or classes of policyholders of the insurer

- persons acting on behalf of the members of that class or those classes.

The meaning of class for this purpose is given at IPTM3630.

Excluded Policies

A life policy, life annuity or capital redemption policy is ‘excluded’ if:

  • the policy or contract is itself a PPB

  • the value of any benefits under the policy or contract is determinable directly or indirectly by reference to a PPB

  • a PPB is property related to the policy or contract.

Cash

Cash includes sums in bank or building society accounts, but not cash that is acquired in order to realise a gain on its disposal.

Specified interests in collective investment schemes

An interest in collective investment schemes are units in non-UK unit trusts or any other arrangement that creates rights in the nature of co-ownership under the law of a territory outside the UK. More information can be found in IPTM7745.

More detailed guidance, aimed largely at insurers and practitioners, is given at IPTM7700 onwards.

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