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HMRC internal manual

Insurance Policyholder Taxation Manual

Person liable to charge: multiple interests

It is quite common for more than one person to own the rights in a policy. The general rule is that each interested person is chargeable on the share of the total gain which is the same as their share in the policy rights, or share of the debt which the policy is used to secure. In most cases there is no difficulty. For example, joint interests of domestic partners are treated as equal shares and the gain is split 50-50.

In some cases different persons may hold rights of a different kind. For example, one person may hold a right to death benefit only while another may hold an additional right to critical illness benefit under the same policy. In these circumstances any gain is divided among the different persons on a just and reasonable basis and generally this will reflect the parties’ self assessments.

Further reference and feedback IPTM1013