keep The Personal Portfolio Bonds (Tax) (Amendment) Regulations 2002
The Personal Portfolio Bonds (Tax) (Amendment) Regulations 2002 amend the Personal Portfolio Bonds (Tax) Regulations 1999, modifying section 552 of the Income and Corporation Taxes Act 1988. The amendments change: the threshold condition for chargeable events (now exceeding one-half of the basic rate limit); reporting requirements for chargeable events; the definition of 'appropriate policy holder'; time periods for reporting; and attribution of gains to tax years. Section 552ZA(3) is also omitted. These are technical amendments to a anti-avoidance regime governing life insurance policies where the policy holder retains control of assets.
This is a targeted anti-avoidance regime for personal portfolio bonds—life insurance policies where the policy holder retains control over asset selection, historically used to defer or avoid capital gains tax. While any regulation carries costs, this regime addresses a specific tax avoidance mechanism with genuine revenue implications. The modifications in 2002 were largely procedural improvements rather than expansions of the underlying rules. Removal would create a significant loophole enabling tax deferral on investment gains without economic substance, undermining the capital gains tax base.