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A Revenue tax calculation recently issued for 1999-2000 did not take account of top slicing relief on an insurance policy chargeable event when calculating the capital gains tax liability. The circumstances of the case are fairly unusual, as the client's income was very low and the chargeable event relatively small, but there were substantial capital gains.
A Revenue tax calculation recently issued for 1999-2000 did not take account of top slicing relief on an insurance policy chargeable event when calculating the capital gains tax liability. The circumstances of the case are fairly unusual as the client's income was very low and the chargeable event relatively small but there were substantial capital gains.
No top slicing relief was required for calculation of the income tax liability since total income was well within the basic rate band. However the similar top slicing relief due under section 6(3)(a) Taxation of Chargeable Gains Act 1992 was not given in the Revenue's calculation although it was confirmed that the relevant number of years had been correctly input onto the computer.
The Inspector has now agreed that top slicing relief is due. I have been advised that the Revenue software is unable to...
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