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Calculating top-slicing relief

26 September 2017 / Tim Good
Issue: 4617 / Categories: Comment & Analysis

It’s all gone Pete Tong


  • Is tax being overcharged on non-qualifying life policies?
  • Commercial software replicates HMRC’s calculation method.
  • Dispelling the myth that top-slicing relief is relevant only for higher and additional rate taxpayers.
  • The three steps of calculating relieved liability under ITTOIA 2005 s 536.
  • Worked examples comparing HMRC’s approach and the legislation.
  • Reopening assessments and recalculating liabilities?

In his article ‘The heat is on’ (Taxation 10 September 2009) Richard Curtis questioned HMRC’s application of the rules for top-slicing relief on non-qualifying policy gains. It seems that nothing came of Richard’s valiant effort to correct an obvious error (if I recall correctly this was ‘a novel interpretation of the legislation’ according to HMRC – Ed). Well perhaps the time has come.

Not only do I agree with Richard’s analysis I have now codified (by way of an Excel spreadsheet) the correct application of the rules as he and I believe them to be....

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