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09 June 2005 / Ralph Davis , Doug Ramage
Issue: 4011 / Categories: Forum & Feedback

Correspondence from readers on topical issues.

Still more uncertain?

I refer to the article by John Woolley entitled ' Still Uncertain ' ( Taxation 19 May 2005, page 190).

I have queried the subject of pre-18 March 1986 regular premium policies with the Inland Revenue Capital Taxes Technical Group. The Inland Revenue confirms that such a policy (commencing before 18 March 1986 but with premiums continuing subsequently) in trust of which the settlor is a potential beneficiary is indeed within the pre-owned asset tax régime.

Correspondence from readers on topical issues.

Still more uncertain?

I refer to the article by John Woolley entitled ' Still Uncertain ' ( Taxation 19 May 2005 page 190).

I have queried the subject of pre-18 March 1986 regular premium policies with the Inland Revenue Capital Taxes Technical Group. The Inland Revenue confirms that such a policy (commencing before 18 March 1986 but with premiums continuing subsequently) in trust of which the settlor is a potential beneficiary is indeed within the pre-owned asset tax régime.

The Revenue has stated in a letter dated 18 May 2005:

'While the policy may be subject to the income tax charge as stated in my letter of 18 April it may not necessarily be the whole value policy. Only the proportion of the value of the policy which is attributable to post-18 March 1986 premiums will be subject to the income tax...

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