Income Tax (Trading and Other Income) Act 2005 section 471

Determination of shares etc.

Section 471 sets out how to determine each person's share of rights in a life insurance policy or capital redemption contract where those rights are held jointly by, or used as security for debts owed by, two or more persons, so that each person's taxable gain can be calculated.

• Where policy or contract rights are jointly owned by two or more persons, those rights are treated as owned in equal shares unless the rules on debt security apply.
• Where policy rights are held as security for debts owed by multiple persons, each debtor is treated as the sole debtor for a notional separate debt, and their share of any gain is proportionate to their share of the total debt secured.
• Property held for the purposes of a foreign institution is treated as beneficially owned by that institution.
• Where a person holds an interest in only some of the rights under a policy (rather than a proportionate share of all the rights), that interest is converted into a share of the total rights on a just and reasonable basis.