Income Tax (Trading and Other Income) Act 2005 section 469

Two or more persons interested in policy or contract

Section 469 deals with how gains (and deficiencies) from life insurance policies or capital redemption contracts are apportioned and taxed when two or more persons hold material interests in the same policy or contract immediately before a chargeable event.

• Where two or more persons hold material interests in a policy or contract immediately before a chargeable event, the gain is split in proportion to each person's share of the rights under that policy or contract
• Each person with a material interest is treated independently for the purposes of determining who is liable to tax, as though no other person held an interest at that time
• Deficiency relief is similarly apportioned: each person's deficiency is calculated as the proportion of the total deficiency that corresponds to their share of the rights
• Where one person holds multiple material interests (for example, one beneficially and one as trustee), each interest is treated separately — unless that person is the sole interest-holder and holds all interests in the same capacity