The surrender took place in the second tax year after that in which the premium was paid so in calculating the gain on the surrender of the policy the amount of allowable premiums in ‘total deductions’ must be restricted by the amount of rebate, namely to £192,000.
She paid a total of £105,000 in premiums into all policies
in the tax year ended 5 April 2008. Since this exceeds
£100,000 and policy A is surrendered in the third tax year
after that in which the premium threshold is crossed, in
calculating the gain on the surrender of policy A the amount of
allowable premiums in ‘total deductions’ must be
restricted by the amount of rebate, namely to £72,000.
There is no effect on the calculation of the gain on policy B
since there was no rebate of commission in respect of the
additional premium paid on it.
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