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HMRC internal manual

Inheritance Tax Manual

Life Policies: life policy linked with an annuity: annuity and policy issued by different companies

Back-to-back arrangements are sometimes entered into with two different insurance companies, usually on arrangement by a financial advisor. One company will sell the annuity and another issue the life policy. It is quite possible for the associated operations provisions to apply in these circumstances. It might be, for example, that

  • the two companies are members of the same group


  • the two companies operate a reinsurance arrangement (an arrangement under which one ‘sells’ its business to the other).

You should bear these possibilities in mind when if the question arises.