Offshore Bond Jurisdictions for UK Residents: Isle of Man, Guernsey, Jersey, Ireland and Luxembourg Compared
Isle of Man, Guernsey, Jersey, Ireland and Luxembourg compared for UK residents and UK-connected families. A UK resident is taxed the same way on a policy from any of them, with no FSCS cover; what differs is the regulator, the governing law and what protects you if the insurer fails.
Five insurer domiciles, one UK tax treatment
For a UK resident, a policy from the Isle of Man, Guernsey, Jersey, Ireland or Luxembourg is taxed the same way. What changes is who regulates the insurer, what protects you if it fails and who may sell to you. Answer nine questions to see the five ranked on those differences. Nothing you enter is sent anywhere and no email address is asked for.
The five at a glance
Listed alphabetically. The UK tax treatment is identical in every row. A profile is marked checked only where the regulator, the governing law and the failure protection were all verified; otherwise it says what requires further review.
| Jurisdiction | If the insurer fails | UK tax | FSCS | Status |
|---|---|---|---|---|
| Guernsey | No compensation scheme for policyholders (Guernsey's scheme covers bank deposits only). A standard licence condition requires the insurer's assets representing at least 90% of policyholder liabilities to be held in trust by a Guernsey trustee, who certifies the assets to the GFSC at least quarterly and must report to it if the insurer orders payments of 5% or more of the trust assets within one calendar month. Nothing is guaranteed: the 90% is a floor on assets held in trust, not a payout, and it is a licence condition rather than a section of the Law. | Foreign policy rules, no basic-rate credit. Same as the other four. | None | Checked on regulator, law and failure protection |
| Ireland | No compensation scheme for life policies: the Insurance Compensation Fund excludes "health, dental and life policies" and covers non-life Irish risks only, paying the lower of 65% of the claim or EUR 825,000. Life policyholders rely on the Solvency II priority for insurance claims in a winding-up (Directive 2009/138/EC Art. 275, transposed by S.I. 485/2015) and on the matching of unit-linked assets. | Foreign policy rules, no basic-rate credit. Same as the other four. | None | Checked on regulator, law and failure protection |
| Isle of Man | Life Assurance (Compensation of Policyholders) Regulations 1991: the scheme pays 90% of the insurer's liability under the contract, with no monetary cap per policy or per policyholder, wherever the policyholder lives (reg 9(1)). It is not funded in advance: after a failure each other life insurer can be levied up to 2% of its own protected long-term liabilities (reg 7(1)), and payments may be deferred or reduced if the fund is short (reg 9(2)). Claims must be made within 6 months of learning of the insolvency and in any case within 18 months (reg 10(1)). Investment losses are not covered. | Foreign policy rules, no basic-rate credit. Same as the other four. | None | Checked on regulator, law and failure protection |
| Jersey | No compensation scheme for insurance policyholders (the Jersey Bank Depositors Compensation Scheme covers bank deposits only) and no trust or custodian rule like Guernsey's. A Category B insurer must keep its long-term business assets in a separate fund used only for that business (Art. 26); a Category A insurer relies on its home jurisdiction's protection. The Code of Practice only requires the insurer to tell policyholders what protection applies, or that none does (para 4.4). | Foreign policy rules, no basic-rate credit. Same as the other four. | None | Checked on regulator, law and failure protection |
| Luxembourg | No compensation scheme for life policies. The assets covering technical provisions form a separate pool charged with a privilege for insurance claims that ranks ahead of every other privilege (Art. 118), with a privileged claim on the general estate for any shortfall (Art. 119). The assets are deposited with a credit institution under an agreement between insurer, bank and CAA (Art. 117(2); CAA circular 16/9), and in a winding-up unit-linked policyholders rank first on the proceeds of the assets behind their units (Art. 253-5). It is a priority claim, not a State guarantee: it is worth what the segregated assets are worth. | Foreign policy rules, no basic-rate credit. Same as the other four. | None | Checked on regulator, law and failure protection |
Start here
The insurer's domicile does not change your UK tax
With the policy, growth inside it is not taxed each year; tax waits for a chargeable event and is then charged as savings income, with top-slicing relief and, for years spent abroad, time apportionment. That is the same whether the insurer sits in Douglas, St Peter Port, St Helier, Dublin or Luxembourg. None of the five gives a UK resident a tax advantage the others lack.
What the domicile does decide is narrower: which regulator supervises the insurer, which law governs it, and what stands between you and a loss if it fails. None of them is covered by the UK Financial Services Compensation Scheme. The personal portfolio bond rules, which limit what a UK resident can hold inside the policy, apply equally in all five.
Everything the tool uses is open below. Each field carries its source and the date it was checked; a field that could not be verified is marked and left out of any conclusion.
Why the jurisdiction still matters
Regulator, governing law and failure protection: the three things that differ.
A UK family choosing between the five is choosing an insurer's home rules, not a tax result. The chargeable event regime in ITTOIA 2005 Part 4 Chapter 9 taxes a gain on a policy from any of them in the same way, and HMRC says gains on foreign policies, unlike gains on UK policies, "do not attract a non-repayable basic rate tax credit" (HS321). The trade is gross roll-up inside the policy against the full marginal rate on the way out.
What differs is the protection if the insurer fails. The Isle of Man scheme pays 90% of the insurer's liability under the contract, with no monetary cap, but it is not funded in advance: after a failure each other life insurer can be levied up to 2% of its own protected liabilities, and payments may be deferred or reduced (Life Assurance (Compensation of Policyholders) Regulations 1991, regs 7 and 9). Guernsey has no compensation scheme; a standard licence condition requires assets representing at least 90% of policyholder liabilities to be held in trust by a Guernsey trustee (GFSC). Ireland's Insurance Compensation Fund excludes life policies, so a policyholder relies on the Solvency II winding-up priority (Central Bank of Ireland). Luxembourg charges the assets covering technical provisions with a privilege for policyholders that ranks ahead of every other privilege, the super-privilege, and those assets sit with a bank under an agreement between insurer, bank and regulator (Law of 7 December 2015, Arts 117 to 119). Jersey has no compensation scheme and no trust rule; only one Jersey-incorporated insurer, Gemlux Life, can write life business, and most policies sold there come from insurers authorised elsewhere, whose home rules then apply (Insurance Business (Jersey) Law 1996).
None of this is the FSCS. The FSCS protects 100% of a long-term insurance claim with no upper limit, but only where the insurer is authorised by the Prudential Regulation Authority (FSCS); a policy issued from the head office of an insurer in any of the five is not.
The investment menu does not widen with the domicile either. If you, a connected person or someone acting for you can select property outside the permitted categories in ITTOIA s.520, the policy is a personal portfolio bond and a deemed gain of 15% of the premiums and earlier deemed gains is taxed each year whether or not you take any money out. A Luxembourg dedicated fund, a Guernsey or Isle of Man bond with a bespoke mandate: the UK test is the same. The personal portfolio bond rules are explained in full elsewhere.
A worked example: £5 million, long-term UK resident, additional-rate taxpayer
Hypothetical figures. The same numbers apply in all five jurisdictions.
Hypothetical. A long-term UK resident pays a single premium of £5,000,000 into a policy with an insurer in any of the five. Other income is already above £125,140, so gains fall in the additional rate band: 45% for 2026/27 and 47% from 6 April 2027 (Finance Act 2026 s.5). Growth of 5% a year after charges is assumed, not forecast. There is no basic-rate credit on any of the five.
| Scenario | Formula | Result |
|---|---|---|
| Full surrender after 10 years, permitted funds only | £5,000,000 × 1.0510 = £8,144,473; gain £3,144,473 × 45% | £1,415,013 of income tax |
| The same gain at the rates from 6 April 2027 | £3,144,473 × 47% | £1,477,902 of income tax |
| Bespoke portfolio chosen by or for you (a PPB), year 1 | 15% × £5,000,000 = £750,000 deemed gain × 45% | £337,500 of tax, with no cash paid out |
| The same PPB, year 2, no withdrawals | 15% × (£5,000,000 + £750,000) = £862,500 × 45% | £388,125 of tax |
| Held personally at death after 10 years, long-term resident | (£8,144,473 − £325,000 nil-rate band) × 40%, assuming the full nil-rate band is available; no residence nil-rate band, which is lost once the estate exceeds £2,350,000 | £3,127,789 of inheritance tax, in all five |
Top-slicing relief does not reduce the rate here because other income already uses the higher bands. With no other income in the year of surrender, the relief (N = 10, with the personal allowance, the £5,000 starting rate and the savings allowance recomputed on the £314,447 slice) would bring the tax to £1,267,043 for 2026/27, or £1,328,932 at the rates from 6 April 2027. The PPB charge compounds because each year's deemed gain is added to the base, and it gets no top-slicing relief. The death is also a chargeable event, so the gain is taxed as income in the final tax year as well. The gains here exceed £18,850, so the insurer's certificate also goes to HMRC. None of these figures depends on the jurisdiction, which is why the selector ranks the five only on the points where they differ.
How to read a result
Match scores, watch-outs and the evidence state behind every field.
Match score out of 100
The weighted average of eight criterion scores from 0 to 10, times ten. Your UK tax is identical in all five and scores the same, so the order comes from protection if the insurer fails, the regulator, who may sell to you, local grant costs on death and the other criteria. It is not a rating of a named insurer.
Watch-outs and constraints
Each row names its main watch-out. A rule that moves a score, such as the loss of UK passporting for Irish and Luxembourg insurers, is listed with its source under "How this ranking was built". Where the law leaves a point to the insurer or to market practice, the score is set cautiously and says so.
Verified means the statement in the field matches the cited primary source, or HMRC guidance, on the date shown. It does not verify a particular insurer, policy or transaction. Where a statement relies on a secondary source it is attributed and marked as requiring further review.
The full comparison: five jurisdictions, twelve fields
The same dataset the engine runs on, with the evidence state of each cell.
Built from the same dataset as the tool, so the two cannot drift apart. Rows that read the same in every column are shown in full deliberately, because identical UK treatment is itself the finding.
| Field | Guernsey | Ireland | Isle of Man | Jersey | Luxembourg |
|---|---|---|---|---|---|
| Regulator | Guernsey Financial Services Commission (GFSC), which licenses insurers under the Insurance Business (Bailiwick of Guernsey) Law, 2002. At 31 December 2025 it recorded 15 commercial life insurers and 36 commercial life insurer cells, both unchanged on a year earlier.VerifiedGFSC, insurance statistics | Central Bank of Ireland, which authorises and supervises insurers under the European Union (Insurance and Reinsurance) Regulations 2015 and has administered the Insurance Compensation Fund since the Insurance (Amendment) Act 2018.VerifiedCentral Bank of Ireland, Insurance Compensation Fund | Isle of Man Financial Services Authority (IOMFSA), formed in 2015 from the Financial Supervision Commission and the Insurance and Pensions Authority. It authorises life insurers under the Insurance Act 2008 and manages the policyholder compensation scheme. At 31 March 2025 it listed 12 authorised life insurers (Classes 1, 2 and 10) and 4 permitted life insurers.VerifiedIOMFSA, summary of registrations and licences | Jersey Financial Services Commission (JFSC), which issues permits under the Insurance Business (Jersey) Law 1996. On its register the only Jersey-incorporated insurer able to write life business is Gemlux Life Limited (Category B, composite); the other 48 (40 long-term, 8 composite) are Category A permit holders authorised in their home jurisdictions, such as the UK, Ireland, Luxembourg, the Isle of Man or Malta.VerifiedJFSC, regulated entities register (insurance) | Commissariat aux Assurances (CAA), which licenses and supervises insurers under the Law of 7 December 2015 on the insurance sector. There were 28 life insurers under Luxembourg law at the end of 2025 and again at 1 July 2026 (29 at the end of 2024, 30 at the end of 2023).VerifiedCAA, annex to the annual report 2025/2026, Tab. 2.1 |
| Governing insurance law | Insurance Business (Bailiwick of Guernsey) Law, 2002, with GFSC licence conditions. Insurers are licensed for general or long-term business; a long-term insurer must appoint a Guernsey actuary, who signs off new products and certifies annually, and an independent Guernsey trustee.VerifiedGFSC, licensed insurers | European Union (Insurance and Reinsurance) Regulations 2015, S.I. No. 485 of 2015, which transpose Solvency II from 1 January 2016. Part 9 applies the prudent person principle (Reg. 141) and requires unit-linked liabilities to be matched as closely as possible by the linked assets; Reg. 142 lets the Central Bank restrict linkable assets only for policies of natural persons and no more tightly than the UCITS rules.VerifiedS.I. No. 485 of 2015, Regs 141 and 142 | Insurance Act 2008, with the Insurance Regulations 2025 (in force 30 June 2025, replacing the 2021 Regulations) and the Insurance (Long-Term Business Valuation and Solvency) Regulations 2018, a risk-based regime calibrated to a 1-in-200-year event and substantially based on Solvency II. Long-term business covers contracts that must run for at least 5 years and normally cannot be ended by the insurer before then.VerifiedInsurance Act 2008; Insurance Regulations 2025; IOMFSA, 1 July 2025 | Insurance Business (Jersey) Law 1996 (revised 27 February 2024). Category A permits are for insurers regulated in their home jurisdiction; Category B insurers are fully Jersey regulated, with solvency margins (Art. 24), an appointed actuary for long-term business (Art. 25) and a separate long-term business fund (Art. 26). The Insurance Business Code of Practice has applied since 17 January 2022.VerifiedInsurance Business (Jersey) Law 1996, Arts 7 and 24 to 26 | Law of 7 December 2015 on the insurance sector (Solvency II; consolidated 3 April 2026) and Law of 27 July 1997 on the insurance contract (consolidated 25 November 2025), with CAA circulars: LC 26/1 on unit-linked investment rules replaced LC 15/3 for new contracts from 1 February 2026, and LC 16/9 on the deposit of assets was amended by LC 26/2 from the same date.VerifiedLaw of 7 December 2015 (consolidated 3 April 2026); Law of 27 July 1997; CAA LC 26/1 and LC 26/2 |
| If the insurer failsDifferent mechanisms, not scored | No compensation scheme for policyholders (Guernsey's scheme covers bank deposits only). A standard licence condition requires the insurer's assets representing at least 90% of policyholder liabilities to be held in trust by a Guernsey trustee, who certifies the assets to the GFSC at least quarterly and must report to it if the insurer orders payments of 5% or more of the trust assets within one calendar month. Nothing is guaranteed: the 90% is a floor on assets held in trust, not a payout, and it is a licence condition rather than a section of the Law.VerifiedGFSC, condition for insurers writing long-term business | No compensation scheme for life policies: the Insurance Compensation Fund excludes "health, dental and life policies" and covers non-life Irish risks only, paying the lower of 65% of the claim or EUR 825,000. Life policyholders rely on the Solvency II priority for insurance claims in a winding-up (Directive 2009/138/EC Art. 275, transposed by S.I. 485/2015) and on the matching of unit-linked assets.VerifiedInsurance Act 1964 ss.3 and 6, as amended 2011 and 2018; Central Bank of Ireland, Insurance Compensation Fund explanation note | Life Assurance (Compensation of Policyholders) Regulations 1991: the scheme pays 90% of the insurer's liability under the contract, with no monetary cap per policy or per policyholder, wherever the policyholder lives (reg 9(1)). It is not funded in advance: after a failure each other life insurer can be levied up to 2% of its own protected long-term liabilities (reg 7(1)), and payments may be deferred or reduced if the fund is short (reg 9(2)). Claims must be made within 6 months of learning of the insolvency and in any case within 18 months (reg 10(1)). Investment losses are not covered.VerifiedLife Assurance (Compensation of Policyholders) Regulations 1991, regs 7, 9 and 10 | No compensation scheme for insurance policyholders (the Jersey Bank Depositors Compensation Scheme covers bank deposits only) and no trust or custodian rule like Guernsey's. A Category B insurer must keep its long-term business assets in a separate fund used only for that business (Art. 26); a Category A insurer relies on its home jurisdiction's protection. The Code of Practice only requires the insurer to tell policyholders what protection applies, or that none does (para 4.4).VerifiedInsurance Business (Jersey) Law 1996, Arts 24 and 26; Insurance Business Code of Practice, para 4.4 | No compensation scheme for life policies. The assets covering technical provisions form a separate pool charged with a privilege for insurance claims that ranks ahead of every other privilege (Art. 118), with a privileged claim on the general estate for any shortfall (Art. 119). The assets are deposited with a credit institution under an agreement between insurer, bank and CAA (Art. 117(2); CAA circular 16/9), and in a winding-up unit-linked policyholders rank first on the proceeds of the assets behind their units (Art. 253-5). It is a priority claim, not a State guarantee: it is worth what the segregated assets are worth.VerifiedLaw of 7 December 2015, Arts 117 to 121 and 253-5 |
| UK FSCS cover | None. The FSCS protects 100% of a long-term insurance claim, with no upper limit, but only for policies of insurers authorised by the Prudential Regulation Authority (PRA Rulebook, Policyholder Protection 4.3(1)). A policy issued from an insurer's head office here is outside it. Whether a policy written through a PRA-authorised UK branch would be covered has not been verified.VerifiedPRA Rulebook, Policyholder Protection 1.2, 4.3(1) and 9.2; FSCS, insurance | None. The FSCS protects 100% of a long-term insurance claim, with no upper limit, but only for policies of insurers authorised by the Prudential Regulation Authority (PRA Rulebook, Policyholder Protection 4.3(1)). A policy issued from an insurer's head office here is outside it. Whether a policy written through a PRA-authorised UK branch would be covered has not been verified.VerifiedPRA Rulebook, Policyholder Protection 1.2, 4.3(1) and 9.2; FSCS, insurance | None. The FSCS protects 100% of a long-term insurance claim, with no upper limit, but only for policies of insurers authorised by the Prudential Regulation Authority (PRA Rulebook, Policyholder Protection 4.3(1)). A policy issued from an insurer's head office here is outside it. Whether a policy written through a PRA-authorised UK branch would be covered has not been verified.VerifiedPRA Rulebook, Policyholder Protection 1.2, 4.3(1) and 9.2; FSCS, insurance | None. The FSCS protects 100% of a long-term insurance claim, with no upper limit, but only for policies of insurers authorised by the Prudential Regulation Authority (PRA Rulebook, Policyholder Protection 4.3(1)). A policy issued from an insurer's head office here is outside it. Whether a policy written through a PRA-authorised UK branch would be covered has not been verified.VerifiedPRA Rulebook, Policyholder Protection 1.2, 4.3(1) and 9.2; FSCS, insurance | None. The FSCS protects 100% of a long-term insurance claim, with no upper limit, but only for policies of insurers authorised by the Prudential Regulation Authority (PRA Rulebook, Policyholder Protection 4.3(1)). A policy issued from an insurer's head office here is outside it. Whether a policy written through a PRA-authorised UK branch would be covered has not been verified.VerifiedPRA Rulebook, Policyholder Protection 1.2, 4.3(1) and 9.2; FSCS, insurance |
| UK tax on gains | Taxed as a foreign policy under ITTOIA 2005 Part 4 Chapter 9. Nothing is taxed while the policy is held, unless it is a personal portfolio bond. A chargeable event gain is savings income at 20, 40 or 45% in 2026/27 and at 22, 42 or 47% from 6 April 2027 (Finance Act 2026 ss.3 and 5, Royal Assent 18 March 2026), with no basic-rate credit because the policy is not written through a UK branch (ITTOIA s.531). The personal allowance (£12,570), the £5,000 starting rate for savings and the personal savings allowance (£1,000, £500 or nil) can absorb part of a gain, and top-slicing relief (s.535) can lower the rate. The same in all five.VerifiedITTOIA 2005 ss.530, 531 and 535; Finance Act 2026 ss.3 and 5; HS321 (2026) | Taxed as a foreign policy under ITTOIA 2005 Part 4 Chapter 9. Nothing is taxed while the policy is held, unless it is a personal portfolio bond. A chargeable event gain is savings income at 20, 40 or 45% in 2026/27 and at 22, 42 or 47% from 6 April 2027 (Finance Act 2026 ss.3 and 5, Royal Assent 18 March 2026), with no basic-rate credit because the policy is not written through a UK branch (ITTOIA s.531). The personal allowance (£12,570), the £5,000 starting rate for savings and the personal savings allowance (£1,000, £500 or nil) can absorb part of a gain, and top-slicing relief (s.535) can lower the rate. The same in all five.VerifiedITTOIA 2005 ss.530, 531 and 535; Finance Act 2026 ss.3 and 5; HS321 (2026) | Taxed as a foreign policy under ITTOIA 2005 Part 4 Chapter 9. Nothing is taxed while the policy is held, unless it is a personal portfolio bond. A chargeable event gain is savings income at 20, 40 or 45% in 2026/27 and at 22, 42 or 47% from 6 April 2027 (Finance Act 2026 ss.3 and 5, Royal Assent 18 March 2026), with no basic-rate credit because the policy is not written through a UK branch (ITTOIA s.531). The personal allowance (£12,570), the £5,000 starting rate for savings and the personal savings allowance (£1,000, £500 or nil) can absorb part of a gain, and top-slicing relief (s.535) can lower the rate. The same in all five.VerifiedITTOIA 2005 ss.530, 531 and 535; Finance Act 2026 ss.3 and 5; HS321 (2026) | Taxed as a foreign policy under ITTOIA 2005 Part 4 Chapter 9. Nothing is taxed while the policy is held, unless it is a personal portfolio bond. A chargeable event gain is savings income at 20, 40 or 45% in 2026/27 and at 22, 42 or 47% from 6 April 2027 (Finance Act 2026 ss.3 and 5, Royal Assent 18 March 2026), with no basic-rate credit because the policy is not written through a UK branch (ITTOIA s.531). The personal allowance (£12,570), the £5,000 starting rate for savings and the personal savings allowance (£1,000, £500 or nil) can absorb part of a gain, and top-slicing relief (s.535) can lower the rate. The same in all five.VerifiedITTOIA 2005 ss.530, 531 and 535; Finance Act 2026 ss.3 and 5; HS321 (2026) | Taxed as a foreign policy under ITTOIA 2005 Part 4 Chapter 9. Nothing is taxed while the policy is held, unless it is a personal portfolio bond. A chargeable event gain is savings income at 20, 40 or 45% in 2026/27 and at 22, 42 or 47% from 6 April 2027 (Finance Act 2026 ss.3 and 5, Royal Assent 18 March 2026), with no basic-rate credit because the policy is not written through a UK branch (ITTOIA s.531). The personal allowance (£12,570), the £5,000 starting rate for savings and the personal savings allowance (£1,000, £500 or nil) can absorb part of a gain, and top-slicing relief (s.535) can lower the rate. The same in all five.VerifiedITTOIA 2005 ss.530, 531 and 535; Finance Act 2026 ss.3 and 5; HS321 (2026) |
| Personal portfolio bond rules | The personal portfolio bond rules apply whatever the domicile. If the policyholder, a connected person or someone acting for them may select property outside the permitted categories of ITTOIA s.520 (insurer internal linked funds, authorised unit trusts, OEICs, investment trusts, REITs, other collective investment schemes, authorised contractual schemes and Reserved Investor Funds, cash, and policies that are not themselves PPBs), a deemed gain arises at the end of every insurance year except the last: 15% of (total premiums + earlier deemed gains minus earlier part-surrender gains) (s.522). It is taxed at the marginal savings rate with no top-slicing relief.VerifiedITTOIA 2005 ss.516, 520, 522 and 535 | The personal portfolio bond rules apply whatever the domicile. If the policyholder, a connected person or someone acting for them may select property outside the permitted categories of ITTOIA s.520 (insurer internal linked funds, authorised unit trusts, OEICs, investment trusts, REITs, other collective investment schemes, authorised contractual schemes and Reserved Investor Funds, cash, and policies that are not themselves PPBs), a deemed gain arises at the end of every insurance year except the last: 15% of (total premiums + earlier deemed gains minus earlier part-surrender gains) (s.522). It is taxed at the marginal savings rate with no top-slicing relief.VerifiedITTOIA 2005 ss.516, 520, 522 and 535 | The personal portfolio bond rules apply whatever the domicile. If the policyholder, a connected person or someone acting for them may select property outside the permitted categories of ITTOIA s.520 (insurer internal linked funds, authorised unit trusts, OEICs, investment trusts, REITs, other collective investment schemes, authorised contractual schemes and Reserved Investor Funds, cash, and policies that are not themselves PPBs), a deemed gain arises at the end of every insurance year except the last: 15% of (total premiums + earlier deemed gains minus earlier part-surrender gains) (s.522). It is taxed at the marginal savings rate with no top-slicing relief.VerifiedITTOIA 2005 ss.516, 520, 522 and 535 | The personal portfolio bond rules apply whatever the domicile. If the policyholder, a connected person or someone acting for them may select property outside the permitted categories of ITTOIA s.520 (insurer internal linked funds, authorised unit trusts, OEICs, investment trusts, REITs, other collective investment schemes, authorised contractual schemes and Reserved Investor Funds, cash, and policies that are not themselves PPBs), a deemed gain arises at the end of every insurance year except the last: 15% of (total premiums + earlier deemed gains minus earlier part-surrender gains) (s.522). It is taxed at the marginal savings rate with no top-slicing relief.VerifiedITTOIA 2005 ss.516, 520, 522 and 535 | The personal portfolio bond rules apply whatever the domicile. If the policyholder, a connected person or someone acting for them may select property outside the permitted categories of ITTOIA s.520 (insurer internal linked funds, authorised unit trusts, OEICs, investment trusts, REITs, other collective investment schemes, authorised contractual schemes and Reserved Investor Funds, cash, and policies that are not themselves PPBs), a deemed gain arises at the end of every insurance year except the last: 15% of (total premiums + earlier deemed gains minus earlier part-surrender gains) (s.522). It is taxed at the marginal savings rate with no top-slicing relief.VerifiedITTOIA 2005 ss.516, 520, 522 and 535 |
| Chargeable event certificates and UK tax representative | The insurer must send the policyholder a chargeable event certificate within 3 months of the event (for a part-surrender excess, of the end of the insurance year), and must also send one to HMRC where the gain exceeds £18,850, half the £37,700 basic rate limit, or where the whole policy is assigned for value (ICTA 1988 s.552). An overseas insurer whose UK premiums reach £1,000,000 must nominate a UK tax representative within 3 months, unless HMRC approves another arrangement (s.552A).VerifiedICTA 1988 ss.552(3) and 552A | The insurer must send the policyholder a chargeable event certificate within 3 months of the event (for a part-surrender excess, of the end of the insurance year), and must also send one to HMRC where the gain exceeds £18,850, half the £37,700 basic rate limit, or where the whole policy is assigned for value (ICTA 1988 s.552). An overseas insurer whose UK premiums reach £1,000,000 must nominate a UK tax representative within 3 months, unless HMRC approves another arrangement (s.552A).VerifiedICTA 1988 ss.552(3) and 552A | The insurer must send the policyholder a chargeable event certificate within 3 months of the event (for a part-surrender excess, of the end of the insurance year), and must also send one to HMRC where the gain exceeds £18,850, half the £37,700 basic rate limit, or where the whole policy is assigned for value (ICTA 1988 s.552). An overseas insurer whose UK premiums reach £1,000,000 must nominate a UK tax representative within 3 months, unless HMRC approves another arrangement (s.552A).VerifiedICTA 1988 ss.552(3) and 552A | The insurer must send the policyholder a chargeable event certificate within 3 months of the event (for a part-surrender excess, of the end of the insurance year), and must also send one to HMRC where the gain exceeds £18,850, half the £37,700 basic rate limit, or where the whole policy is assigned for value (ICTA 1988 s.552). An overseas insurer whose UK premiums reach £1,000,000 must nominate a UK tax representative within 3 months, unless HMRC approves another arrangement (s.552A).VerifiedICTA 1988 ss.552(3) and 552A | The insurer must send the policyholder a chargeable event certificate within 3 months of the event (for a part-surrender excess, of the end of the insurance year), and must also send one to HMRC where the gain exceeds £18,850, half the £37,700 basic rate limit, or where the whole policy is assigned for value (ICTA 1988 s.552). An overseas insurer whose UK premiums reach £1,000,000 must nominate a UK tax representative within 3 months, unless HMRC approves another arrangement (s.552A).VerifiedICTA 1988 ss.552(3) and 552A |
| New arrivals and the FIG regime | Chargeable event gains are not qualifying foreign income (ITTOIA s.845H), so the 4-year FIG regime that replaced the remittance basis from 6 April 2025 does not shelter them: a gain is taxed on the arising basis in the FIG years too. A FIG claim also costs the personal allowance and the CGT annual exempt amount for that year (ss.845E and 845G). The relief for a new arrival is time apportionment for the days of non-UK residence in the material interest period (s.528).VerifiedITTOIA 2005 ss.528, 845E, 845G and 845H; RFIG45100 | Chargeable event gains are not qualifying foreign income (ITTOIA s.845H), so the 4-year FIG regime that replaced the remittance basis from 6 April 2025 does not shelter them: a gain is taxed on the arising basis in the FIG years too. A FIG claim also costs the personal allowance and the CGT annual exempt amount for that year (ss.845E and 845G). The relief for a new arrival is time apportionment for the days of non-UK residence in the material interest period (s.528).VerifiedITTOIA 2005 ss.528, 845E, 845G and 845H; RFIG45100 | Chargeable event gains are not qualifying foreign income (ITTOIA s.845H), so the 4-year FIG regime that replaced the remittance basis from 6 April 2025 does not shelter them: a gain is taxed on the arising basis in the FIG years too. A FIG claim also costs the personal allowance and the CGT annual exempt amount for that year (ss.845E and 845G). The relief for a new arrival is time apportionment for the days of non-UK residence in the material interest period (s.528).VerifiedITTOIA 2005 ss.528, 845E, 845G and 845H; RFIG45100 | Chargeable event gains are not qualifying foreign income (ITTOIA s.845H), so the 4-year FIG regime that replaced the remittance basis from 6 April 2025 does not shelter them: a gain is taxed on the arising basis in the FIG years too. A FIG claim also costs the personal allowance and the CGT annual exempt amount for that year (ss.845E and 845G). The relief for a new arrival is time apportionment for the days of non-UK residence in the material interest period (s.528).VerifiedITTOIA 2005 ss.528, 845E, 845G and 845H; RFIG45100 | Chargeable event gains are not qualifying foreign income (ITTOIA s.845H), so the 4-year FIG regime that replaced the remittance basis from 6 April 2025 does not shelter them: a gain is taxed on the arising basis in the FIG years too. A FIG claim also costs the personal allowance and the CGT annual exempt amount for that year (ss.845E and 845G). The relief for a new arrival is time apportionment for the days of non-UK residence in the material interest period (s.528).VerifiedITTOIA 2005 ss.528, 845E, 845G and 845H; RFIG45100 |
| Inheritance tax | Since 6 April 2025 the test is long-term UK residence, not domicile: UK resident in at least 10 of the previous 20 tax years (IHTA 1984 s.6A). A policy from a non-UK insurer is a non-UK asset, so it is excluded property for someone who is not long-term resident and in the estate at 40% for someone who is. The nil-rate band (£325,000), the residence nil-rate band (£175,000, tapered by £1 for every £2 of estate above £2,000,000) and the taper threshold are frozen to 5 April 2031 (FA 2026 s.72). A leaver stays long-term resident for 3 to 10 years.VerifiedIHTA 1984 s.6A; FA 2021 s.86 as amended by FA 2026 s.72; IHTM47020 | Since 6 April 2025 the test is long-term UK residence, not domicile: UK resident in at least 10 of the previous 20 tax years (IHTA 1984 s.6A). A policy from a non-UK insurer is a non-UK asset, so it is excluded property for someone who is not long-term resident and in the estate at 40% for someone who is. The nil-rate band (£325,000), the residence nil-rate band (£175,000, tapered by £1 for every £2 of estate above £2,000,000) and the taper threshold are frozen to 5 April 2031 (FA 2026 s.72). A leaver stays long-term resident for 3 to 10 years.VerifiedIHTA 1984 s.6A; FA 2021 s.86 as amended by FA 2026 s.72; IHTM47020 | Since 6 April 2025 the test is long-term UK residence, not domicile: UK resident in at least 10 of the previous 20 tax years (IHTA 1984 s.6A). A policy from a non-UK insurer is a non-UK asset, so it is excluded property for someone who is not long-term resident and in the estate at 40% for someone who is. The nil-rate band (£325,000), the residence nil-rate band (£175,000, tapered by £1 for every £2 of estate above £2,000,000) and the taper threshold are frozen to 5 April 2031 (FA 2026 s.72). A leaver stays long-term resident for 3 to 10 years.VerifiedIHTA 1984 s.6A; FA 2021 s.86 as amended by FA 2026 s.72; IHTM47020 | Since 6 April 2025 the test is long-term UK residence, not domicile: UK resident in at least 10 of the previous 20 tax years (IHTA 1984 s.6A). A policy from a non-UK insurer is a non-UK asset, so it is excluded property for someone who is not long-term resident and in the estate at 40% for someone who is. The nil-rate band (£325,000), the residence nil-rate band (£175,000, tapered by £1 for every £2 of estate above £2,000,000) and the taper threshold are frozen to 5 April 2031 (FA 2026 s.72). A leaver stays long-term resident for 3 to 10 years.VerifiedIHTA 1984 s.6A; FA 2021 s.86 as amended by FA 2026 s.72; IHTM47020 | Since 6 April 2025 the test is long-term UK residence, not domicile: UK resident in at least 10 of the previous 20 tax years (IHTA 1984 s.6A). A policy from a non-UK insurer is a non-UK asset, so it is excluded property for someone who is not long-term resident and in the estate at 40% for someone who is. The nil-rate band (£325,000), the residence nil-rate band (£175,000, tapered by £1 for every £2 of estate above £2,000,000) and the taper threshold are frozen to 5 April 2031 (FA 2026 s.72). A leaver stays long-term resident for 3 to 10 years.VerifiedIHTA 1984 s.6A; FA 2021 s.86 as amended by FA 2026 s.72; IHTM47020 |
| Automatic exchange (CRS) | Guernsey has applied the Common Reporting Standard since 1 January 2016, with first reporting in 2017, under CRS Regulations 2015 amended in 2020, 2021 and 2025; Bulletin 2025/2 introduces the CRS 2.0 changes. Its FATCA agreement with the US has been in force since 26 August 2015. A policy with a cash value is reported, and the data is exchanged with HMRC.VerifiedStates of Guernsey, CRS; US Treasury, FATCA agreements | Cash value policies of Irish insurers are reportable under the Common Reporting Standard and the data is exchanged with HMRC. Ireland's FATCA agreement with the US has been in force since 2 April 2014. Its own CRS rules are in S.I. No. 583 of 2015, with collection from 1 January 2016 and returns due by 30 June.VerifiedHMRC IEIM400580; US Treasury, FATCA agreements | The Isle of Man has applied the Common Reporting Standard since 1 January 2016, with first exchanges in September 2017. Its FATCA agreement with the US has been in force since 26 August 2015. Cash value policies are reportable and the data is exchanged with HMRC.VerifiedIsle of Man Government, FATCA and CRS | Cash value policies are reportable under the Common Reporting Standard and the data is exchanged with HMRC. Jersey's FATCA agreement with the US has been in force since 28 October 2015. Jersey's CRS rules apply from 1 January 2016, with the first exchange in 2017.VerifiedHMRC IEIM400580; US Treasury, FATCA agreements | Luxembourg transposed the Common Reporting Standard by the Law of 18 December 2015; insurers report to the Administration des contributions directes by 30 June of the following year. The Law of 27 March 2026 brings in CRS 2.0 with effect from 1 January 2026, and the first reports under the new rules are due by 30 June 2027. Cash value and unit-linked policies are reportable, and the data is exchanged with HMRC.VerifiedLaw of 18 December 2015; Law of 27 March 2026; ACD, CRS |
| US person in the family: IRC 4371 treaty route | Guernsey has no income tax treaty with the US and is not on the IRS list of 16 treaty countries exempting premiums from the US excise tax (updated 22 March 2026). A premium paid for a US person bears 1 cent per dollar or part of a dollar (IRC 4371(2)), payable by the premium payer on Form 720, unless the insurer has elected under IRC 953(d) to be taxed as a US company.VerifiedIRC 4371, 4374 and 953(d); IRS, exemption from section 4371 excise tax | Ireland is on the IRS list of 16 treaty countries (updated 22 March 2026). The 1997 US-Ireland convention exempts premiums only where the risk is not reinsured with a person outside an exempting treaty, the insurer meets the limitation on benefits article, and a closing agreement with the IRS is in effect (Rev. Proc. 2003-78). Otherwise 1 cent per dollar or part of a dollar is due (IRC 4371(2)), payable by the premium payer on Form 720. Ask whether the Irish insurer holds a closing agreement.VerifiedUS-Ireland Convention 1997, Art. 2(1)(a); IRC 4371; Rev. Proc. 2003-78 | The Isle of Man has no income tax treaty with the US and is not on the IRS list of 16 treaty countries exempting premiums from the US excise tax (updated 22 March 2026). A premium paid for a US person bears 1 cent per dollar or part of a dollar (IRC 4371(2)), payable by the premium payer on Form 720, unless the insurer has elected under IRC 953(d) to be taxed as a US company.VerifiedIRC 4371, 4374 and 953(d); IRS, exemption from section 4371 excise tax | Jersey has no income tax treaty with the US and is not on the IRS list of 16 treaty countries exempting premiums from the US excise tax (updated 22 March 2026). A premium paid for a US person bears 1 cent per dollar or part of a dollar (IRC 4371(2)), payable by the premium payer on Form 720, unless the insurer has elected under IRC 953(d) to be taxed as a US company.VerifiedIRC 4371, 4374 and 953(d); IRS, exemption from section 4371 excise tax | Luxembourg is on the IRS list of 16 treaty countries (updated 22 March 2026), for direct insurance premiums only, not reinsurance. The exemption needs a closing agreement between the IRS and the insurer (Rev. Proc. 2003-78), and no Luxembourg life insurer appeared on the IRS closing agreement lists read in September 2026. Without one, 1 cent per dollar or part of a dollar is due (IRC 4371(2)), payable by the premium payer on Form 720.VerifiedUS-Luxembourg Convention 1996, Art. 2; IRC 4371; Rev. Proc. 2003-78 |
| Writing through a UK branch | A policy is taxed like a UK policy, with a non-repayable credit at the savings basic rate (20%, or 22% from 2027/28) and no gross roll-up, only where the non-UK insurer lawfully carries on life business in the UK through a UK permanent establishment and the premiums are paid to it and form part of its business receipts (ITTOIA s.531, Conditions A and B; ICTA 1988 Sch 15 para 24(3)). A policy issued from the head office here does not meet that test. Ask whether the insurer writes UK business through a UK branch.VerifiedITTOIA 2005 ss.530 and 531(3)(b); ICTA 1988 Sch 15 para 24(3); FA 2026 Sch 1 para 44 | A policy is taxed like a UK policy, with a non-repayable credit at the savings basic rate (20%, or 22% from 2027/28) and no gross roll-up, only where the non-UK insurer lawfully carries on life business in the UK through a UK permanent establishment and the premiums are paid to it and form part of its business receipts (ITTOIA s.531, Conditions A and B; ICTA 1988 Sch 15 para 24(3)). A policy issued from the head office here does not meet that test. Ask whether the insurer writes UK business through a UK branch.VerifiedITTOIA 2005 ss.530 and 531(3)(b); ICTA 1988 Sch 15 para 24(3); FA 2026 Sch 1 para 44 | A policy is taxed like a UK policy, with a non-repayable credit at the savings basic rate (20%, or 22% from 2027/28) and no gross roll-up, only where the non-UK insurer lawfully carries on life business in the UK through a UK permanent establishment and the premiums are paid to it and form part of its business receipts (ITTOIA s.531, Conditions A and B; ICTA 1988 Sch 15 para 24(3)). A policy issued from the head office here does not meet that test. Ask whether the insurer writes UK business through a UK branch.VerifiedITTOIA 2005 ss.530 and 531(3)(b); ICTA 1988 Sch 15 para 24(3); FA 2026 Sch 1 para 44 | A policy is taxed like a UK policy, with a non-repayable credit at the savings basic rate (20%, or 22% from 2027/28) and no gross roll-up, only where the non-UK insurer lawfully carries on life business in the UK through a UK permanent establishment and the premiums are paid to it and form part of its business receipts (ITTOIA s.531, Conditions A and B; ICTA 1988 Sch 15 para 24(3)). A policy issued from the head office here does not meet that test. Ask whether the insurer writes UK business through a UK branch.VerifiedITTOIA 2005 ss.530 and 531(3)(b); ICTA 1988 Sch 15 para 24(3); FA 2026 Sch 1 para 44 | A policy is taxed like a UK policy, with a non-repayable credit at the savings basic rate (20%, or 22% from 2027/28) and no gross roll-up, only where the non-UK insurer lawfully carries on life business in the UK through a UK permanent establishment and the premiums are paid to it and form part of its business receipts (ITTOIA s.531, Conditions A and B; ICTA 1988 Sch 15 para 24(3)). A policy issued from the head office here does not meet that test. Ask whether the insurer writes UK business through a UK branch.VerifiedITTOIA 2005 ss.530 and 531(3)(b); ICTA 1988 Sch 15 para 24(3); FA 2026 Sch 1 para 44 |
| Main limits for a UK family | No compensation scheme: protection is a trust over assets worth at least 90% of policyholder liabilities, which is a floor on segregated assets, not a payout. A small life market: 15 commercial life insurers and 36 life cells at 31 December 2025. UK tax, PPB and IHT treatment are exactly as for the other four. This row summarises the rows above rather than citing a separate source.Requires further review | No compensation fund for life policies; the policyholder relies on the winding-up priority and asset matching. Two Irish charges do not reach a UK resident: the 1% life assurance levy applies only to risks located in Ireland (SDCA 1999 s.124B), and a policy issued from 1 January 2001 is outside Irish capital acquisitions tax where neither the disponer nor the beneficiary is Irish domiciled or ordinarily resident (CATCA 2003 s.74). UK tax, PPB and IHT treatment are exactly as for the other four. This row summarises the rows above rather than citing a separate source.Requires further review | The scheme pays 90%, not 100%, is funded only after a failure, and its capacity is limited by the 2% levy on the surviving insurers; payment can take several years. There is no statutory trust or custodian rule, and the market is small (12 authorised life insurers). UK tax, PPB and IHT treatment are exactly as for the other four. This row summarises the rows above rather than citing a separate source.Requires further review | Jersey is mainly a place where insurers from elsewhere hold permits, not a home for offshore bond insurers: one Jersey-incorporated life-capable insurer, no compensation scheme and no trust rule. For a policy sold in Jersey by a Category A insurer, the protection is that of the insurer's home jurisdiction. UK tax, PPB and IHT treatment are exactly as for the other four. This row summarises the rows above rather than citing a separate source.Requires further review | No compensation scheme: the super-privilege is a ranking over segregated assets, not a guarantee of value. It does not widen what a UK resident may hold: the PPB rules decide the investment menu, and a Luxembourg dedicated fund chosen or directed for the policyholder is not a UK safe harbour. US-connected premiums normally bear the 1% excise, as no Luxembourg life insurer appears on the IRS closing-agreement lists. UK tax and IHT treatment are exactly as for the other four. This row summarises the rows above rather than citing a separate source.Requires further review |
Considered but not profiled
A UK insurer for comparison, Bermuda, and UK branches of non-UK insurers.
These come up in UK conversations about offshore bonds. They are not profiled because the evidence for UK readers is incomplete, or because they are not a PPLI domicile at all.
A UK insurer (onshore bond) Not profiled
What is known. The useful comparison for a UK resident. A gain on a UK policy carries a non-repayable credit at the savings basic rate, 20% now and 22% from 2027/28 (ITTOIA s.530; FA 2026 Sch 1 para 44), because the insurer is taxed on its fund. The FSCS protects 100% of a long-term insurance claim with no upper limit where the insurer is authorised by the PRA (PRA Rulebook, Policyholder Protection 4.3(1)).
- Not a PPLI domicile: included only to show what the offshore policy gives up (the credit and the FSCS) in exchange for gross roll-up.
Bermuda Not profiled
What is known. For a UK resident a Bermuda policy is a foreign policy like the five above: same chargeable event rules, no basic-rate credit, same PPB rules, no FSCS. The Bermuda Monetary Authority supervises insurers under the Insurance Act 1978; there is no compensation scheme, and protection rests on the ring-fenced long-term business fund (s.24) and, for segregated accounts companies, account segregation (Segregated Accounts Companies Act 2000 s.17). Bermuda is not on the IRS treaty list for the US excise tax.
- Bermuda is not listed in Schedule 2 of the Financial Promotion Order 2005, so a Bermuda insurer that is not itself UK authorised cannot use the promotion exemptions available to Isle of Man, Guernsey and Jersey insurers (art 10).
- Bermuda is not ranked here because its insurers cannot use the UK promotion exemptions.
A UK branch of a non-UK insurer Not profiled
What is known. A policy written through the UK permanent establishment of a non-UK insurer, with the premiums paid to that establishment and forming part of its receipts, is taxed like a UK policy: a credit at the savings basic rate and no gross roll-up (ITTOIA s.531, Conditions A and B; ICTA 1988 Sch 15 para 24(3)).
- Ask each insurer whether it writes UK business through a UK branch.
- Ask whether FSCS cover extends to a policy written through a PRA-authorised UK branch.
Methodology
What the nine questions change, how each criterion is scored and how the ranking is built.
What the tool does
It asks nine questions and ranks the five domiciles for you on eight criteria: tax and entry cost, insurer protection, investment flexibility, estate and succession, privacy and reporting, portability, regulatory strength and administrative simplicity. Each is scored from 0 to 10 from sources checked on 24 September 2026, and the reason, citation and evidence state of every score are shown with the result. It also calculates, at your amount, the figures that are the same in all five: the 5% allowance, the personal portfolio bond charge, inheritance tax exposure, a lifetime transfer into trust and, where a US person is insured, the US excise.
What it does not do
It does not assess an insurer's solvency, charges or service, approve an investment list, or test a particular policy against the PPB rules. It does not model company ownership in detail or the tax of the country you move to.
The nine questions
Your position with the UK, years of UK residence (for long-term residence), US-person status, who holds the policy, the premium (band midpoint, £10,000,000 for the open band, or an exact amount), withdrawals, how the investments are chosen, your priorities and whether you or your heirs may live abroad. Every question has a default, so a result is always computed.
How each criterion is scored
Insurer protection: 10 would need segregated assets in independent custody, a first-rank privilege and a payout scheme together, and none of the five has all three. 9 for Luxembourg's segregated assets with a first-rank privilege and bank custody, but no compensation scheme; 9 for the Isle of Man, where assets at least equal to technical provisions are reserved for policyholders and a compensation scheme pays 90% with no cap, funded after a failure, but no independent custodian is required; 8 for Guernsey's trust over at least 90% of liabilities, with no scheme; 6 for Ireland's winding-up priority, 4 for Jersey, which has neither a scheme nor a trust rule. Estate and succession: 9 where no death duty applies, less 2 points for each 1% of the premium a local grant would cost on a policy held personally (Isle of Man, Guernsey and Jersey fees are computed at your amount). Portability: 9 for the Crown Dependencies while you stay in the UK, because they are in Schedule 2 of the Financial Promotion Order; Irish and Luxembourg insurers are capped at 5 for UK residents, having lost UK passporting on 31 December 2020, and score 8 with their EU passport if you are leaving, live abroad or live in a Crown Dependency; in those positions the Crown Dependency insurers, which carry no EU passport, score 6. Tax and entry cost is identical in all five unless a US person is insured. Where a US person is insured or owns the policy, investment flexibility is capped at 6 everywhere by IRC 817(h).
Weights
Without priorities, protection weighs 2.5, regulation 2, investment, estate and portability 1.5 and the rest 1; if you are leaving the UK or live outside it, including in a Crown Dependency, portability weighs 2.5. Choosing priorities sets your first to 3, the second to 2 and the third to 1.5, and every other criterion to 1. A yes on heirs abroad raises portability to at least 2 (not sure: at least 1.5), even if you ranked it lower among your priorities. Ties go to insurer protection, then tax and entry cost, then regulatory strength.
Status of a profile
In the summary table and the full comparison, three fields decide whether a profile is described as checked: regulator, governing insurance law and failure protection. If any is not verified, the table says so and names the gap.
Source order
Statute, then HMRC manuals and helpsheets, then the regulator's own pages. A statement from a law firm or promotion agency is attributed and marked as requiring further review.
The formulas
Every figure the tool shows can be reproduced by hand.
Eight criteria, each scored 0 to 10. Ties go to insurer protection, then tax and entry cost, then regulatory strength.
Applied to a policy held personally, at the premium amount. Estate score = 9 − 2 × cost as a % of the premium, capped at a 3-point reduction.
A is total premiums paid, B the total of earlier deemed gains, C the total of earlier part-surrender gains (ITTOIA s.522). It arises at the end of every insurance year except the last and is taxed at your marginal savings rate, with no top-slicing relief and no basic-rate credit.
Withdrawals are tax-deferred up to 5% of each premium for each insurance year, including the year it is paid, cumulative and capped at 100% of the premium after 20 years; any excess is a gain at the end of that insurance year (ITTOIA ss.507 and 509). The 5% withdrawals come back into the final gain. Taxed as savings income at 20, 40 or 45% for 2026/27 and at 22, 42 or 47% from 6 April 2027, with the personal allowance of £12,570 (lost at £1 for every £2 of adjusted net income above £100,000), the £5,000 starting rate for savings and the personal savings allowance of £1,000, £500 or nil.
N is the number of complete policy years: from the start for a full surrender, from the last excess for a part-surrender excess on a policy issued or varied from 6 April 2013. The basic-rate credit is notional for a foreign policy, used only in this computation. Since Finance Act 2020 s.37 the personal allowance, and in HMRC practice from 2021/22 the starting rate and savings allowance, are recomputed as if only the slice were received (ITTOIA s.535). Individuals only; not for PPB deemed gains.
A is the number of foreign days, the days of non-UK residence of the person liable plus the overseas part of any split year, in the material interest period; B is the total days (ITTOIA s.528). Apply it before top-slicing relief, and reduce N by the whole years of non-residence. It is also available to trustees taxed on a deceased settlor's gain (s.528A).
For a personally held policy of a long-term UK resident. Nil-rate band £325,000; residence nil-rate band up to £175,000 for a home left to direct descendants, reduced by £1 for every £2 of estate above £2,000,000; both frozen to 5 April 2031 (FA 2026 s.72). 36% where at least 10% of the net estate goes to charity.
1 cent per dollar or part of a dollar (IRC 4371(2)), charged in dollars and paid by the premium payer on Form 720. Shown only where a US person is in the family; removable only with an IRS closing agreement for Ireland or Luxembourg, or where the insurer has elected under IRC 953(d).
Sources and authorities
Legislation, HMRC manuals and regulators, each with the date checked.
https://www.gfsc.gg/industry-sectors/insurance/statistics Checked 31 December 2025
https://www.gfsc.gg/industry-sectors/type-insurance-entity/licensed-insurers Checked 24 September 2026
https://www.gfsc.gg/sites/default/files/Standard-Condition-for%20Life-Companies-(for-information-only).pdf Checked 24 September 2026
https://www.fscs.org.uk/what-we-cover/products/insurance/ Checked 24 September 2026
https://www.legislation.gov.uk/ukpga/2026/11/section/5/enacted Checked 18 March 2026
https://www.legislation.gov.uk/ukpga/2005/5/section/522 Checked 24 September 2026
https://www.legislation.gov.uk/ukpga/1988/1/section/552 Checked 24 September 2026
https://www.gov.uk/hmrc-internal-manuals/residence-and-fig-regime-manual/rfig45100 Checked 24 September 2026
https://www.legislation.gov.uk/ukpga/1984/51/section/6A Checked 24 September 2026
https://www.gov.gg/crs Checked 24 September 2026
https://www.irs.gov/businesses/international-businesses/exemption-from-section-4371-excise-tax Checked 22 March 2026
https://www.legislation.gov.uk/ukpga/2005/5/section/531 Checked 24 September 2026
https://www.centralbank.ie/regulation/industry-market-sectors/insurance-reinsurance/insurance-compensation-fund Checked 3 October 2025
https://www.irishstatutebook.ie/eli/2015/si/485/made/en/print Checked 24 September 2026
https://www.centralbank.ie/docs/default-source/regulation/industry-market-sectors/insurance-reinsurance/insurance-compensation-fund/gns-4-4-10-1-9---insurance-compensation-fund-ex-note.pdf?sfvrsn=a789d11d_14 Checked 30 November 2018
https://www.gov.uk/hmrc-internal-manuals/international-exchange-of-information/ieim400580 Checked 31 July 2026
https://www.iomfsa.im/statistics-site/summary-of-registrations-and-licences/ Checked 31 March 2025
https://www.iomfsa.im/fsa-news/2025/jul/updated-regulations-aim-to-enhance-competitiveness-of-insurance-sector/ Checked 1 July 2025
https://legislation.gov.im/cms/images/LEGISLATION/SUBORDINATE/1991/1991-G048/1991-G048_1.pdf Checked 24 September 2026
https://www.gov.im/categories/tax-vat-and-your-money/income-tax-and-national-insurance/international-agreements/fatca-and-common-reporting-standard/ Checked 24 September 2026
https://www.jerseyfsc.org/industry/regulated-entities?lawSectionIns=1 Checked 24 September 2026
https://www.jerseylaw.je/laws/current/l_12_1996 Checked 27 February 2024
https://www.jerseyfsc.org/industry/codes-of-practice/insurance-business-code-of-practice/ Checked 17 January 2022
https://www.caa.lu/uploads/documents/files/CAA_RA_2025_annexes.pdf Checked 28 July 2026
https://legilux.public.lu/eli/etat/leg/loi/2015/12/07/n1/consolide/20260403 Checked 3 April 2026
https://impotsdirects.public.lu/fr/echanges_electroniques/CRS_NCD.html Checked 9 September 2026
https://www.gov.uk/government/publications/gains-on-foreign-life-insurance-policies-hs321-self-assessment-helpsheet/hs321-gains-on-foreign-life-insurance-policies-2026 Checked 24 September 2026
https://www.legislation.gov.uk/ukpga/2005/5/section/507 Checked 24 September 2026
https://www.legislation.gov.uk/ukpga/2005/5/section/535 Checked 24 September 2026
https://www.legislation.gov.uk/ukpga/2020/14/section/37 Checked 24 September 2026
https://www.legislation.gov.uk/ukpga/2005/5/section/520 Checked 24 September 2026
https://www.legislation.gov.uk/ukpga/2005/5/section/528 Checked 24 September 2026
https://www.legislation.gov.uk/ukpga/2026/11/section/9 Checked 24 September 2026
https://www.legislation.gov.uk/ukpga/2026/11/section/72 Checked 24 September 2026
https://www.gov.uk/apply-tax-free-interest-on-savings/how-much-is-tax-free Checked 24 September 2026
https://www.gov.uk/hmrc-internal-manuals/insurance-policyholder-taxation-manual/iptm3734 Checked 24 September 2026
https://www.gov.uk/hmrc-internal-manuals/insurance-policyholder-taxation-manual/iptm7730 Checked 24 September 2026
https://www.iomfsa.im/consumer-material/compensation-scheme-life-assurance/ Checked 24 September 2026
https://www.law.cornell.edu/uscode/text/26/4371 Checked 24 September 2026
https://www.legislation.gov.uk/uksi/2005/1529/schedule/2 Checked 24 September 2026
What this tool is not
Limits, stated as part of the result.
- It covers five domiciles. Others are listed above as not profiled, and their absence is not a judgement about them.
- A ranking is not a recommendation. It weighs framework facts for the answers you give; it does not assess a named insurer.
- It says nothing about a particular insurer's strength, charges or service. Those come from the insurer and its documents.
- Figures use 2026/27 rates for England, Wales and Northern Ireland unless a later date is stated; savings income is taxed at the same UK rates in Scotland. Rates from 6 April 2027 are labelled.
- It does not model trusts, companies or estates in detail, the temporary non-residence charge in the year of return, or the tax of the country you move to.
- Where a primary source could not be opened, the field is marked rather than estimated, and the mark should be read as part of the result.
PPLI.com is not authorised by the Financial Conduct Authority and does not give personal advice. This is general information about UK law, not an invitation or inducement to enter into any insurance or investment contract. Policies issued by insurers outside the UK are not protected by the Financial Services Compensation Scheme.
Review status and versions
No named professional has signed off this dataset yet.
No named independent professional has reviewed this dataset or tool. Every field is traceable to its source and date, and fields that could not be verified are marked. Before approval it needs review by a UK private client tax adviser (chargeable events, PPB, residence and IHT) and, for the protection rows, lawyers qualified in each jurisdiction.
Editorial responsibility: Eldar Edmond Grady, CEO, PPLI.com, under our editorial standards.
- Last checked
- 24 September 2026
- Dataset
- 2026.09.24-uk
- Methodology
- 1.1.0-uk
- Engine
- 1.1.0-uk
- Review status
- No independent professional sign-off
- Selector
- 1.0.0; five domiciles, eight criteria (data 2026.09.25-sel-uk)
- Coverage
- 5 jurisdictions profiled; 3 considered and not profiled
Related UK research
Where to go next
To model tax drag, break-even and liquidity events beyond the choice of jurisdiction, the UK tools are collected in Wealth Intelligence. Editorial responsibility and who we are: About PPLI.com.