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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. Top slicing relief: how relief is given

IPTM3840 | Top slicing relief: how relief is given

From HM Revenue & Customs · Insurance Policyholder Taxation Manual

Top slicing relief is given in terms of tax reduction. A common misconception is to enter on the tax return the gain divided by the number of years. This is incorrect. The full amount of the gain should be returned. Several steps are involved in the computation, which depends on whether there is a single chargeable event during the tax year, or more than one.

For the purposes of calculating top slicing relief, chargeable event gains are treated as the top slice of total income.

One chargeable event

Step 1: Calculate the total taxable income for the year and identify how much of the gain falls within the starting rate for savings, personal savings allowance nil rate, basic, higher or additional rate bands as appropriate.

Step 2: Calculate the total tax due on the gain across all tax bands. Deduct basic rate tax treated as paid to find the total liability for the tax year.

Step 3: Calculate the annual equivalent of the gain. The annual equivalent is calculated by dividing the gain by N (as determined in IPTM3830).

Step 4: Calculate the individual’s liability to tax on the annual equivalent. Deduct basic rate tax treated as paid on the annual equivalent and multiply the result by N. This gives the total relieved liability.

Step 5: Deduct the total relieved liability at step 4 from the total liability at step 2 to give the amount of top slicing relief due.

Two or more chargeable events

Steps 1 and 2: These are the same as the Steps 1 and 2 where there is just one chargeable event, but instead take the total of the gains on all of the chargeable events. If a policy has given rise to deficiency relief for that tax year – see IPTM3860 – the relief is deducted in calculating the aggregate.

Step 3: Calculate the ‘annual equivalent’ for each gain by dividing it by N (as in IPTM3830) that applies to that gain and then add all these annual equivalents to arrive at the total annual equivalent.

Step 4: Calculate the total liability to tax on the total annual equivalent. Deduct basic rate tax treated as paid on the total annual equivalent.

Step 5: Multiply the result at step 4 by the full gain on the policy.

Step 6: Divide the result at step 5 by the total annual equivalent at step 3. The result is the total relieved liability.

Step 7: Deduct the total relieved liability at step 6 from the total liability at step 2 to give the amount of top slicing relief due.

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