IPTM7195 | Certificates for HMRC: time limits for delivery: general rules: ICTA88/S552(7)

The time limits for insurers to deliver certificates reporting events and gains to HMRC are different from those for delivering certificates to policyholders. An insurer always has at least as long, and in most cases longer, to report events to HMRC as it does to report to policyholders.

Although there is nothing in legislation to prevent an insurer reporting events to HMRC as soon as the event occurs, it is advisable for insurers to wait until the end of the insurance year (policy year) before issuing the certificate. This is because it makes it more likely that the details included are correct and will not need to be revised due to subsequent events or other information coming to light.

General rule

The general rule is that an insurer must deliver the chargeable event certificate to HMRC within three months of the end of the tax year in which the chargeable event occurred. In some circumstances, this general time limit is extended, as described below and in IPTM7200.

A ‘tax year’ is a year ended 5 April (previously known as a ‘year of assessment’).

Statutory extension for part surrender or assignment events

These are events under ITTOIA05/S514(1) where a transaction-related calculation shows a gain.

Part surrender or assignment events can occur at any time during an insurance year, not just at the end of it, so under the general rule described in the previous section the time limit could be before the end of the insurance year. This may cause problems if there are subsequent events in the same insurance year which affect the earlier calculation.

Therefore, where there is a part surrender or assignment event, the insurer has until three months from the end of the insurance year in which the event occurred to deliver the certificate, if that date is later than that indicated by the general rule described in the previous section.

An example is where the event occurs on 25 January 2021 and the insurance year ends on 27 August. The event occurs in the tax year ended 5 April 2021 and three months after this is 5 July 2021, which would be the deadline under the general rule. But three months from the end of the insurance year in which the event occurs is 26 November 2021, so that is the latest reporting date instead.