Corporation Tax Act 2009 section 98/99

Reverse premiums – transitional provisions

Section 98/99 transitional rules exempt certain reverse premiums from the tax charge where they were received or entitled to before 9 March 1999.

• Reverse premiums received before 9 March 1999 are not subject to the tax treatment rules in sections 98 and 99
• Reverse premiums to which the recipient was already entitled immediately before 9 March 1999 are also excluded
• Any arrangements made on or after 9 March 1999 are disregarded when determining whether entitlement existed before that date
• This prevents manipulation of the transitional relief through backdated or new arrangements entered into after the rules took effect