Income Tax (Trading and Other Income) Act 2005 section 472

Trusts created by two or more persons

Section 472 deals with how chargeable event gains on life insurance policies and capital redemption contracts are allocated between multiple settlors where the policy or contract rights are held on non-charitable trusts.

• Where two or more persons created a non-charitable trust holding policy or contract rights, each person is treated as the sole settlor of a separate proportionate share of those rights immediately before a chargeable event.
• Each settlor's share is based on the proportion of the total trust property that originated from that settlor, including where different persons have added property to the trust at different times.
• Property originating from a person includes property they provided for the trusts, property representing that original property, and accumulated income from it, with a just and reasonable apportionment applied where trust property has mixed origins.
• A person is treated as having provided property if they did so directly or indirectly, or if another person provided it under reciprocal arrangements with them — but property that a person contributed under reciprocal arrangements with someone else is not attributed to that person.