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HMRC internal manual

Insurance Policyholder Taxation Manual

Chargeable event guidance for insurers: contents

The chargeable event legislation as it applies to individuals, trustees and personal representatives has now been rewritten under the Tax Law Rewrite Project and is contained in Chapter 9 of Part 4 of ITTOIA05. It was previously contained in Chapter 2 of Part 13 of ICTA88, which also applied to companies. However, from the start of the first accounting period of a company to begin on or after 1 April 2008, companies are taxed under the loan relationships legislation on investment life insurance contracts to which they are a party - IPTM3900 onwards.

The legislation governing reporting requirements of UK insurers remains in ICTA88/S552 and ICTA88/S552ZA, which have been amended slightly to reflect the enactment of ITTOIA05. The qualifying policy rules remain in ICTA88/SCH15.

This guidance will primarily refer to and follow the structure of ITTOIA05, with references to ICTA88 only where appropriate, since in the vast majority of cases chargeable event gains will be taxable under ITTOIA05.