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HMRC internal manual

Insurance Policyholder Taxation Manual

Non-UK policyholder and assignments and shared rights

Assignments between spouses/civil partners

A policy may have been assigned between spouses/civil partners who are living together. If this policy gives rise to a chargeable event gain at some later date after assignment, then the material interest period may be calculated by reference to the period of ownership of both individuals.

Any period during which the transferor met the conditions for the material interest period noted in IPTM3732 is included in the calculation of the total material interest period. This means that for periods during which the individuals were non-UK resident any foreign days during their period of ownership may be included in the calculation of the time apportioned reduction.

Rights under a policy are shared

Rights under a policy include individuals with a share of those rights.

Where a policy is held by more than one individual the calculation of time apportioned reduction will be applied separately to each individual’s share of the gain from the policy, based on their own residence history.