Commentary

E1.452D Life insurance gains—non-UK resident policyholders

Personal and employment tax

E1.452D Life insurance gains—non-UK resident policyholders

E1.452D Life insurance gains—non-UK resident policyholders

Provision is made for a reduction in a gain (after any reduction in respect of restricted relief qualifying policies, see E1.452CA) in respect of periods of non-UK residence. This provision differs in significant respects depending on whether the policy was issued before 6 April 2013 or is issued or varied on or after that date.

Policies issued before 6 April 2013

A gain in respect of a foreign life insurance policy or a foreign capital redemption policy is reduced where there are one of more foreign days in the part of the life of the policy up to the time of the chargeable event (the 'policy period')1. Foreign days are days for which the individual is non-UK resident or days falling within the overseas part of a split tax year2. The reduction does not apply to gains on life annuity contracts.

The gain is reduced by the fraction:

where:

  1.  

         A is the number of days in the policy

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