Income Tax (Trading and Other Income) Act 2005 section 28

Reverse premiums

Section 28 provides transitional rules that exempt certain reverse premiums from the tax charge in sections 101 and 102, based on whether they were received or became due before 9 March 1999.

  • Reverse premiums received before 9 March 1999 are not subject to the tax rules in sections 101 and 102
  • Reverse premiums to which the recipient was already entitled immediately before 9 March 1999 are also exempt from those provisions
  • Any arrangements made on or after 9 March 1999 must be ignored when determining whether the recipient was entitled to the reverse premium before that date
  • The anti-avoidance rule prevents taxpayers from using later arrangements to claim their entitlement arose before the 9 March 1999 cut-off date

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