IPTM7180 - Certificate for HMRC: ‘care of’ addresses, change of addresses and ‘gone away’ cases

Use of ‘care of’ or other addresses

The purpose of requiring the insurer to report the policyholder’s address is to enable HMRC to trace the policyholder and match the gain to the taxpayer. HMRC is entitled to be told the present private address of the policyholder and does not accept that the use of a ‘care of’ address would meet the insurer’s statutory duty save in exceptional circumstances. Two exceptions which have been agreed in the past are the use of the parents’ address for students and the use of the address held on central records for industrial branch business.

A case which is not an exception is where there are personal representatives dealing with the estate of the deceased and a gain arose on the death of the policyholder. Then the insurer should report the private address of the deceased, not the correspondence address of any personal representatives.

Where an insurer feels it has no alternative but to report a ‘care of’ address HMRC would expect the insurer to provide some justification and to have made some enquiries before putting that address on the certificate. These points would be taken into account by HMRC in considering whether or not penalties are due for the failure to provide an address. Such cases are likely to be rare.

Change of address between date of event and date of issuing certificate

Strictly, the address to be shown on the certificate to be sent to HMRC is the address which applied at the date of the chargeable event. However, if the insurer knew that the policyholder’s address had subsequently changed, HMRC would have no objections to the insurer reporting the latest address instead.

‘Gone away’ cases

Clearly, the current private address of the policyholder should be entered on the certificate for HMRC where known. However, there may be exceptional cases where the insurer knows that the private address of the policyholder which it holds is out of date and it is unable to establish a current address. Then, the insurer should report the last known address on the certificate rather than fail to comply with the requirement to report the address or submit the certificate. That information may enable HMRC to trace the taxpayer even if the insurer is unable to do so.