IPTM9190 - Overseas insurers: release from requirement to appoint a tax representative: pre-6 April 2000 policies and contracts: information notices to be provided to HMRC

Information to be provided to HMRC on a pre-6 April 2000 policy or contract

IPTM9180 describes the circumstances in which an overseas insurer must provide information to HMRC about all ‘last events’ – maturity, full surrender or death – in a tax year on pre-6 April 2000 policies and contracts where there is at least one common policyholder.

The information that must be supplied is:

  • the policy reference number for each of the policies on which there has been a last event
  • the name and address of all the policyholders for each policy - see IPTM7175 and IPTM7180 for guidance where there is a difficulty in establishing a current private address for a policyholder, a power of attorney or policies held on trust
  • the date and nature of each of the chargeable events, and
  • the aggregate of the sums and benefits paid by the insurer as a result of the events - but reporting of the individual sums paid on each event would also be acceptable.

Address and format of information notices

There is no prescribed format for sending this information to HMRC but insurers should include the heading ‘Notification of Life Insurance Payment by Overseas Insurer’ to distinguish these information notices from chargeable event certificates that report gains. The name and address of the insurer should also be included in the information notices. Information notices should be sent to HMRC at the address given in IPTM9010.

Time limit for submission of information notices to HMRC

Information notices must be sent to HMRC within three months of the end of the tax year in which the chargeable events occurred. However, there is no reason why insurers should not send in separate notices of events as soon as they become aware that sums paid have exceeded the reporting threshold.

Where an insurer is notified of a death some time after it occurred which causes it to miss the reporting deadline, HMRC will not regard the insurer as being in breach of its reporting undertaking provided it reports details of the event within three months of notification of the death.

Example

Peter held one policy as sole policyholder and one policy jointly with his wife Jane. Both policies came to an end in the tax year ended 5 April 2019. One matured with a sum of £30,000 and the other was surrendered for £50,000.

Peter is a policyholder of both policies and the total proceeds of £80,000 exceed the £69,000 reporting threshold for the year. The insurer must provide a notice to HMRC by 5 July 2019 reporting details of the policies, each event and the total proceeds of the two policies or the proceeds of each. It will also need to give the full name and address of both Peter and Jane and show on the notice that Peter solely held one policy and jointly held the other with Jane.