Income Tax (Trading and Other Income) Act 2005 section 529

Certain pre-20th March 1985 policies: application of section 529(1)

Section 529(1) deals with special rules that limit the exceptions from the charge on gains from foreign life insurance policies and foreign capital redemption policies where those policies were issued on or before 19th March 1985 and were held by non-UK resident trustees on that date.

• This provision applies to foreign life insurance policies issued for insurances made on or before 19th March 1985, and to foreign capital redemption policies issued for contracts made on or before that date.
• Section 529(1) normally provides exceptions that disapply the charge under section 528 where a policy is or was held by a non-UK resident trustee at any relevant time.
• However, the exception for a single non-UK resident trustee does not apply if the policy was already held by a non-UK resident trustee on 19th March 1985.
• Similarly, the exception for multiple trustees (where any is non-UK resident) does not apply if, on 19th March 1985, the policy was held by a non-UK resident trustee or by two or more trustees at least one of whom was non-UK resident.