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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. 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

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

From HM Revenue & Customs · Insurance Policyholder Taxation Manual

There is also a transitional rule that applies where- a company is party to an investment life insurance contract immediately before the ‘start date’ (the start date is the first day of the first AP of the company to start on or after 1 April 2008) - the company accounts for the contract other than at fair value, and - the carrying value of the contract exceeds the fair value at the start date.

If these conditions are met then no non-trading debits can be brought into account on the contract until they exceed the amount by which carrying value exceeded fair value immediately before the start date. In practice, surrender value can normally be taken as fair value. This rule only affects the treatment of debits that arise after the start date. It does not affect the treatment of future credits.Example

The company’s AP is to 30 September each year. It took out a policy on 15 February 2004 with premium of £10,000, which was also the original cost of the contract. It accounts for the policy using historic cost basis.

It surrendered 25% of the rights under the policy on 27 June 2007 for £2,200. The surrender value of the policy on 30 September 2008 is £6,500. The company surrenders a further 50% of the original rights under the policy on 22 May 2010 for £3,500.

AP ended 30 September 2009: The start date is 1 October 2008. The historic cost of the policy immediately before the start date is £7,500 (75% x £10,000, because 25% of the policy has already been surrendered) which exceeds the surrender value (fair value) on that date by £1,000, so the transitional rule applies. This means that the company cannot bring any debits into account in future until they exceed £1,000.

This is of no consequence for this AP since there are no related transactions during the year and as historic cost accounting applies no annual debit or credit arises for this AP.

AP ended 30 September 2010: The part surrender in the year for £3,500 is a related transaction. The cost of the part surrendered is £5,000 (50% x £10,000). Therefore there is a non-trading debit of £1,500 (£3,500 – £5,000). However, only £500 of this debit can be brought into account, since the £1,000 that relates to the period before the start date is not allowed under the transitional rule.

| Further reference and feedback | IPTM1013 | |——————————–|——————————————————————————————————|

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