IPTM3130 - Chargeable events: the
charge to tax: corporation tax: points of difference
This page only applies to events occurring in a
company’s accounting periodstarting before 1 April 2008. For accounting periods
starting on or after 1 April2008, the chargeable event gain rules no longer apply to
investment life policies,purchased life annuity contracts and capital redemption
policies owned bycompanies and instead they are taxed under the loan
relationships rules – seeIPTM3900onwards.
In most cases, the chargeable event regime is the same for
charges on individuals and companies. The differences are
- the restricted scope of chargeable events
that applies in the case of qualifying policies does not apply to
charges on companies - see
IPTM3310
- companies are not entitled to top-slicing
relief -
IPTM3820, to deficiency relief -
IPTM3860, or to tax treated as paid -
see
IPTM3800.
- companies are only chargeable on capital
redemption policies
- when they are issued by non UK-resident
insurers
- from 10 February 2005, on those policies that are
not money debts, such as annuities certain, as otherwise the loan
relationships legislation applies.
The difference in legislative references is discussed at
IPTM1075. The legislation provides for
continuity in relation to policies and contracts that are assigned
between individuals and companies.
