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Onshore/offshore life policies, qualifying & non-qualifying, adviser fees on tax-deferred withdrawals

Investment bonds and top-slicing relief

Fix the category first: a chargeable event gain on an investment bond is INCOME — savings income, added to the client's other income in the year of encashment — never a capital gain, so no annual exempt amount and no CGT rates, however gain-like it looks. That single classification decides half the questions on this node. The problem top-slicing relief solves follows directly: a gain that built up over many years lands in one tax year and can shove the client through bands they never crossed while it accrued. The method, in order and by name: (1) divide the gain by the number of COMPLETE years held to get one slice; (2) tax that single slice on top of the client's other income — recalculating the personal savings allowance and personal allowance for THIS calculation using other income plus the slice, not the full gain (the post-2020 method the exam now expects); (3) multiply the one-slice tax by the number of years — that is the relieved liability. Watch the language: top-slicing changes the RATE the gain suffers; it never reduces the gain itself, and 'complete years' means complete policy years, not calendar years or a rounded guess. Then, separately, onshore bonds carry a basic-rate TAX CREDIT of 20% of the gain — 'tax treated as paid' inside the UK life fund. Precision matters here twice over: it is a credit against the liability, not a deduction from the gain; and it is non-repayable — it can take the bill to zero, never below, and never generates a refund. Offshore bonds have no such credit, because no UK fund tax was suffered; their gains also get the starting rate for savings and PSA in full, but the whole relieved liability is actually payable.

£40,000 onshore gain, 8 complete years, £45,000 other income
Taxable other income after the personal allowance
45,000 - 12,570 = £32,430
Basic-rate band remaining
37,700 - 32,430 = £5,270
The slice: gain over complete years held
40,000 / 8 = £5,000
Tax on one slice (£1,000 PSA for the slice calc, rest at basic rate)
(5,000 - 1,000) * 0.2 = £800
Relieved liability: slice tax × 8
800 * 8 = £6,400
Onshore basic-rate credit on the whole gain
40,000 * 0.2 = £8,000
Net tax due — the credit more than covers the liability
0 = £0

The PSA used in the slice calculation is the £1,000 basic-rate figure because other income plus one slice stays under the higher-rate threshold — recalculating it with the full gain instead is exactly the error HMRC corrected for gains from 2021/22 (IPTM3820, examples at IPTM3850; confirmed in Agent Update 79). The credit is non-repayable: it can take the bill to zero, never below.

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