I refer to the article by John Woolley entitled 'Still Uncertain' in the issue dated 19 May 2005.
I have queried the subject of pre-18 March 1986 regular premium policies with HMRC's Capital Taxes Technical Group. HMRC confirm that such a policy (commencing before 18 March 1986 but with premiums continuing subsequently) in a trust of which the settlor is a potential beneficiary is indeed within the pre-owned assets tax régime.
HMRC have stated in a letter dated 18 May 2005:
I refer to the article by John Woolley entitled ' Still Uncertain ' ( Taxation 19 May 2005, page 190).
I have queried the subject of pre-18 March 1986 regular premium policies with the Inland Revenue Capital Taxes Technical Group. The Inland Revenue confirms that such a policy (commencing before 18 March 1986 but with premiums continuing subsequently) in trust of which the settlor is a potential beneficiary is indeed within the pre-owned asset tax régime.