IPTM7793 | Personal portfolio bonds (PPB): non-resident policyholder becomes UK resident

Where a non-resident policyholder becomes UK resident and the policy is a PPB then, before the end of the insurance year in which the policyholder became UK resident, to escape the PPB charge, either the insurance company must vary the policy conditions so that it is no longer a PPB or the policyholder must surrender the policy.

The PPB legislation is anti-avoidance legislation aimed at preventing a loss to the UK exchequer. However, there is no motive test for the legislation to apply. If a PPB is held by a newly resident policyholder at the end of the insurance year then a PPB gain may arise.