Income Tax (Trading and Other Income) Act 2005 section 534

Gains from contracts for life insurance etc: regulations providing for relief where foreign tax chargeable

Section 534 deals with the transitional rules governing when regulations providing relief for foreign tax on gains from life insurance contracts can take effect.

• Regulations under section 534 may provide relief where foreign tax has been charged on gains from life insurance contracts and similar policies.
• These regulations can apply to gains arising on or after 29 November 1994.
• They can also apply to gains arising before 29 November 1994, provided the related income tax assessment had not become final and conclusive before that date.
• The transitional provisions ensure that earlier gains are not excluded from relief solely because they arose before the key date, as long as the tax position was still open.