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HMRC internal manual

Insurance Policyholder Taxation Manual

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HM Revenue & Customs
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Legislative references: ITTOIA and ICTA

Parallel legislative codes: individuals and companiesThe Income Tax (Trading and Other Income) Act 2005 (ITTOIA05) applies to chargeable event gains where the person liable is an individual or trustee.

The Income and Corporation Taxes Act 1988 (ICTA88) applies where the subject is a company within the charge to corporation tax for accounting periods of the company beginning before 1 April 2008. For accounting periods beginning on or after 1 April 2008 the loan relationships legislation applies instead –IPTM3900 onwards.

As the chargeable events legislation largely focuses on the policy, rather than the person charged, it is often difficult to give a single legislative reference in the text. The use of legislative references has been kept to a minimum, but where they are a useful aid to clarity it is the ITTOIA05 reference that is generally quoted.

The derivation of the ITTOIA05 provision is available in the standard published works, and this may be used to find the corresponding ICTA88 provision where required.

Further reference and feedback IPTM1013