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 and what protects you if it fails. Nothing you enter is sent anywhere and no email address is asked for.
Default result: all five, before you answer anything
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 statutory compensation scheme. Instead, a standard licence condition requires the insurer's assets representing at least 90% of policyholder liabilities to be held in trust. | Foreign policy rules, no basic-rate credit. Same as the other four. | None | Checked on regulator, law and failure protection |
| Ireland | The Insurance Compensation Fund does not cover life policies ("excluded risks include health, dental and life policies"). For non-life it pays the lower of 65% or EUR 825,000. Other protections under Irish and EU law were not checked. | Foreign policy rules, no basic-rate credit. Same as the other four. | None | Requires further review: Governing insurance law |
| Isle of Man | Policyholder Compensation Scheme under the Life Assurance (Compensation of Policyholders) Regulations 1991: up to a maximum of 90% of the value of a protected contract at the date the insurer fails. It covers insurer failure, not investment losses, is funded by levies on other insurers after a failure, and payment may take several years. | Foreign policy rules, no basic-rate credit. Same as the other four. | None | Requires further review: Governing insurance law |
| Jersey | Requires further review. No compensation scheme for long-term business was found in the JFSC legislation list, and no other policyholder protection rule has been verified. Nothing is assumed either way. | Foreign policy rules, no basic-rate credit. Same as the other four. | None | Requires further review: If the insurer fails |
| Luxembourg | Protection rests on segregation and priority, not on a compensation payment. The insurance-sector law gives policyholders a statutory priority over the assets covering their policies (Articles 117 to 119), which the market calls the super-privilege. Luxembourg for Finance describes the wider "triangle of security": assets held with a custodian approved by the CAA under an agreement between insurer, custodian and CAA. The policyholder has a priority claim, not title to the assets. | 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 runs a Policyholder Compensation Scheme that pays up to a maximum of 90% of the value of a protected contract, funded by levies on other insurers after a failure (IOMFSA). Guernsey has no compensation scheme; a standard licence condition requires assets representing at least 90% of policyholder liabilities to be held in trust (GFSC). Ireland's Insurance Compensation Fund excludes life policies (Central Bank of Ireland). Luxembourg gives policyholders a statutory priority over the assets covering their policies, which the market calls the super-privilege, and Luxembourg for Finance describes the custody arrangement around it as the "triangle of security". For Jersey, the protection position requires further review and nothing is assumed.
None of this is the FSCS. The FSCS covers life policies only where the failed insurer was regulated by the Prudential Regulation Authority (FSCS); an insurer based 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% a year is taxed 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 45% band for 2026/27. Growth of 5% a year after charges is assumed, not forecast.
| 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 from 6 April 2027 rates | £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 | 15% × (£5,000,000 + £750,000) = £862,500 × 45% | £388,125 of tax |
| Held personally at death, long-term resident | Policy value in the estate at 40%, before the nil-rate band and exemptions | In scope in all five |
Top-slicing relief does not reduce the rate here because other income already uses the higher bands; it matters more for a policyholder whose other income is lower in the year of surrender. There is no basic-rate credit on any of the five. The PPB charge compounds because each year's deemed gain is added to the base. None of these figures depends on the jurisdiction, which is why the engine does not rank them.
How to read a result
Two labels, and the evidence state behind every field.
Checked on the points that differ
The regulator, the governing insurance law and the failure protection were all verified at source. It is not a recommendation.
Requires further review
At least one of those three could not be verified. The card names which one. The jurisdiction is not marked down for it, but it is not described as checked either.
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 and sets their licence conditions.VerifiedGFSC standard condition for life companies | Central Bank of Ireland.VerifiedCentral Bank of Ireland, Insurance Compensation Fund explanatory note | Isle of Man Financial Services Authority (IOMFSA), which authorises insurers writing long-term business.VerifiedIOMFSA, Compensation Scheme: Life Assurance | Jersey Financial Services Commission (JFSC).VerifiedJFSC, insurance legislation | Commissariat aux Assurances (CAA).VerifiedCAA |
| Governing insurance law | Insurance Business (Bailiwick of Guernsey) Law, 2002, with GFSC licence conditions.VerifiedInsurance Business (Bailiwick of Guernsey) Law, 2002 | Requires further review. The Irish statutes governing life insurers were not opened for this dataset; only the Insurance Act 1964 (as amended), which sets up the Insurance Compensation Fund, was checked.Requires further review | Requires further review. Isle of Man law firms describe the Insurance Act 2008 as the governing statute; the primary text was not opened for this dataset.Requires further reviewLegal 500, Isle of Man insurance guide (secondary) | Insurance Business (Jersey) Law 1996 and related Orders.VerifiedJFSC, insurance legislation | Law of 7 December 2015 on the insurance sector, as amended, with CAA circulars.VerifiedLaw of 7 December 2015 (consolidated text) |
| If the insurer failsDifferent mechanisms, not scored | No statutory compensation scheme. Instead, a standard licence condition requires the insurer's assets representing at least 90% of policyholder liabilities to be held in trust.VerifiedGFSC standard condition for life companies | The Insurance Compensation Fund does not cover life policies ("excluded risks include health, dental and life policies"). For non-life it pays the lower of 65% or EUR 825,000. Other protections under Irish and EU law were not checked.VerifiedCentral Bank of Ireland, Insurance Compensation Fund explanatory note | Policyholder Compensation Scheme under the Life Assurance (Compensation of Policyholders) Regulations 1991: up to a maximum of 90% of the value of a protected contract at the date the insurer fails. It covers insurer failure, not investment losses, is funded by levies on other insurers after a failure, and payment may take several years.VerifiedIOMFSA, Compensation Scheme: Life Assurance | Requires further review. No compensation scheme for long-term business was found in the JFSC legislation list, and no other policyholder protection rule has been verified. Nothing is assumed either way.Requires further reviewJFSC, insurance legislation | Protection rests on segregation and priority, not on a compensation payment. The insurance-sector law gives policyholders a statutory priority over the assets covering their policies (Articles 117 to 119), which the market calls the super-privilege. Luxembourg for Finance describes the wider "triangle of security": assets held with a custodian approved by the CAA under an agreement between insurer, custodian and CAA. The policyholder has a priority claim, not title to the assets.VerifiedLaw of 7 December 2015, Articles 117 to 119; Luxembourg for Finance (description) |
| UK FSCS cover | None. FSCS cover for life policies applies only where the failed insurer was regulated by the Prudential Regulation Authority. An insurer based here is not, so its policies fall outside the FSCS.VerifiedFSCS, what we cover: insurance | None. FSCS cover for life policies applies only where the failed insurer was regulated by the Prudential Regulation Authority. An insurer based here is not, so its policies fall outside the FSCS.VerifiedFSCS, what we cover: insurance | None. FSCS cover for life policies applies only where the failed insurer was regulated by the Prudential Regulation Authority. An insurer based here is not, so its policies fall outside the FSCS.VerifiedFSCS, what we cover: insurance | None. FSCS cover for life policies applies only where the failed insurer was regulated by the Prudential Regulation Authority. An insurer based here is not, so its policies fall outside the FSCS.VerifiedFSCS, what we cover: insurance | None. FSCS cover for life policies applies only where the failed insurer was regulated by the Prudential Regulation Authority. An insurer based here is not, so its policies fall outside the FSCS.VerifiedFSCS, what we cover: insurance |
| UK tax on gains | Taxed as a foreign policy under ITTOIA 2005 Part 4 Chapter 9. No annual tax on growth inside the policy; a chargeable event gain is savings income at 20, 40 or 45% in 2026/27 (22, 42 or 47% from 6 April 2027), with no basic-rate credit because the insurer is outside the UK. Top-slicing relief can apply. The same treatment applies in all five jurisdictions.VerifiedHS321 (2026); IPTM3720 | Taxed as a foreign policy under ITTOIA 2005 Part 4 Chapter 9. No annual tax on growth inside the policy; a chargeable event gain is savings income at 20, 40 or 45% in 2026/27 (22, 42 or 47% from 6 April 2027), with no basic-rate credit because the insurer is outside the UK. Top-slicing relief can apply. The same treatment applies in all five jurisdictions.VerifiedHS321 (2026); IPTM3720 | Taxed as a foreign policy under ITTOIA 2005 Part 4 Chapter 9. No annual tax on growth inside the policy; a chargeable event gain is savings income at 20, 40 or 45% in 2026/27 (22, 42 or 47% from 6 April 2027), with no basic-rate credit because the insurer is outside the UK. Top-slicing relief can apply. The same treatment applies in all five jurisdictions.VerifiedHS321 (2026); IPTM3720 | Taxed as a foreign policy under ITTOIA 2005 Part 4 Chapter 9. No annual tax on growth inside the policy; a chargeable event gain is savings income at 20, 40 or 45% in 2026/27 (22, 42 or 47% from 6 April 2027), with no basic-rate credit because the insurer is outside the UK. Top-slicing relief can apply. The same treatment applies in all five jurisdictions.VerifiedHS321 (2026); IPTM3720 | Taxed as a foreign policy under ITTOIA 2005 Part 4 Chapter 9. No annual tax on growth inside the policy; a chargeable event gain is savings income at 20, 40 or 45% in 2026/27 (22, 42 or 47% from 6 April 2027), with no basic-rate credit because the insurer is outside the UK. Top-slicing relief can apply. The same treatment applies in all five jurisdictions.VerifiedHS321 (2026); IPTM3720 |
| Personal portfolio bond rules | The personal portfolio bond rules apply in full whatever the domicile. If the policyholder, a connected person or someone acting for them can select property outside the permitted categories, a deemed gain of 15% of premiums plus earlier deemed gains is taxed every year, with no top-slicing relief.VerifiedITTOIA 2005 ss.516 and 522; IPTM3650 | The personal portfolio bond rules apply in full whatever the domicile. If the policyholder, a connected person or someone acting for them can select property outside the permitted categories, a deemed gain of 15% of premiums plus earlier deemed gains is taxed every year, with no top-slicing relief.VerifiedITTOIA 2005 ss.516 and 522; IPTM3650 | The personal portfolio bond rules apply in full whatever the domicile. If the policyholder, a connected person or someone acting for them can select property outside the permitted categories, a deemed gain of 15% of premiums plus earlier deemed gains is taxed every year, with no top-slicing relief.VerifiedITTOIA 2005 ss.516 and 522; IPTM3650 | The personal portfolio bond rules apply in full whatever the domicile. If the policyholder, a connected person or someone acting for them can select property outside the permitted categories, a deemed gain of 15% of premiums plus earlier deemed gains is taxed every year, with no top-slicing relief.VerifiedITTOIA 2005 ss.516 and 522; IPTM3650 | The personal portfolio bond rules apply in full whatever the domicile. If the policyholder, a connected person or someone acting for them can select property outside the permitted categories, a deemed gain of 15% of premiums plus earlier deemed gains is taxed every year, with no top-slicing relief.VerifiedITTOIA 2005 ss.516 and 522; IPTM3650 |
| Chargeable event certificates and UK tax representative | The insurer must issue UK chargeable event certificates (ICTA 1988 s.552) on policies taken out after 6 April 2000. A non-UK insurer whose UK policies reach gross premiums of £1 million or more must nominate a UK tax representative within 3 months, unless HMRC agrees otherwise (s.552A).VerifiedICTA 1988 s.552A; IPTM3210 | The insurer must issue UK chargeable event certificates (ICTA 1988 s.552) on policies taken out after 6 April 2000. A non-UK insurer whose UK policies reach gross premiums of £1 million or more must nominate a UK tax representative within 3 months, unless HMRC agrees otherwise (s.552A).VerifiedICTA 1988 s.552A; IPTM3210 | The insurer must issue UK chargeable event certificates (ICTA 1988 s.552) on policies taken out after 6 April 2000. A non-UK insurer whose UK policies reach gross premiums of £1 million or more must nominate a UK tax representative within 3 months, unless HMRC agrees otherwise (s.552A).VerifiedICTA 1988 s.552A; IPTM3210 | The insurer must issue UK chargeable event certificates (ICTA 1988 s.552) on policies taken out after 6 April 2000. A non-UK insurer whose UK policies reach gross premiums of £1 million or more must nominate a UK tax representative within 3 months, unless HMRC agrees otherwise (s.552A).VerifiedICTA 1988 s.552A; IPTM3210 | The insurer must issue UK chargeable event certificates (ICTA 1988 s.552) on policies taken out after 6 April 2000. A non-UK insurer whose UK policies reach gross premiums of £1 million or more must nominate a UK tax representative within 3 months, unless HMRC agrees otherwise (s.552A).VerifiedICTA 1988 s.552A; IPTM3210 |
| New arrivals and the FIG regime | Chargeable event gains are not qualifying foreign income, so the 4-year FIG regime for new arrivals does not shelter them. The relief for a new arrival is time apportionment for days of non-UK residence (ITTOIA s.528).VerifiedITTOIA s.845H; RFIG45100 | Chargeable event gains are not qualifying foreign income, so the 4-year FIG regime for new arrivals does not shelter them. The relief for a new arrival is time apportionment for days of non-UK residence (ITTOIA s.528).VerifiedITTOIA s.845H; RFIG45100 | Chargeable event gains are not qualifying foreign income, so the 4-year FIG regime for new arrivals does not shelter them. The relief for a new arrival is time apportionment for days of non-UK residence (ITTOIA s.528).VerifiedITTOIA s.845H; RFIG45100 | Chargeable event gains are not qualifying foreign income, so the 4-year FIG regime for new arrivals does not shelter them. The relief for a new arrival is time apportionment for days of non-UK residence (ITTOIA s.528).VerifiedITTOIA s.845H; RFIG45100 | Chargeable event gains are not qualifying foreign income, so the 4-year FIG regime for new arrivals does not shelter them. The relief for a new arrival is time apportionment for days of non-UK residence (ITTOIA s.528).VerifiedITTOIA s.845H; RFIG45100 |
| Inheritance tax | The policy is not outside inheritance tax. Held personally by a long-term UK resident (10 of the previous 20 tax years) it is in the estate at 40%. Trusts help only under the normal trust rules, and since 6 April 2025 an excluded property trust shelters non-UK property only while the settlor is not long-term UK resident.VerifiedIHTA 1984 s.6A; HMRC Trusts and Estates Newsletter, April 2025 | The policy is not outside inheritance tax. Held personally by a long-term UK resident (10 of the previous 20 tax years) it is in the estate at 40%. Trusts help only under the normal trust rules, and since 6 April 2025 an excluded property trust shelters non-UK property only while the settlor is not long-term UK resident.VerifiedIHTA 1984 s.6A; HMRC Trusts and Estates Newsletter, April 2025 | The policy is not outside inheritance tax. Held personally by a long-term UK resident (10 of the previous 20 tax years) it is in the estate at 40%. Trusts help only under the normal trust rules, and since 6 April 2025 an excluded property trust shelters non-UK property only while the settlor is not long-term UK resident.VerifiedIHTA 1984 s.6A; HMRC Trusts and Estates Newsletter, April 2025 | The policy is not outside inheritance tax. Held personally by a long-term UK resident (10 of the previous 20 tax years) it is in the estate at 40%. Trusts help only under the normal trust rules, and since 6 April 2025 an excluded property trust shelters non-UK property only while the settlor is not long-term UK resident.VerifiedIHTA 1984 s.6A; HMRC Trusts and Estates Newsletter, April 2025 | The policy is not outside inheritance tax. Held personally by a long-term UK resident (10 of the previous 20 tax years) it is in the estate at 40%. Trusts help only under the normal trust rules, and since 6 April 2025 an excluded property trust shelters non-UK property only while the settlor is not long-term UK resident.VerifiedIHTA 1984 s.6A; HMRC Trusts and Estates Newsletter, April 2025 |
| Automatic exchange (CRS) | Guernsey applied the Common Reporting Standard from 1 January 2016, with first reporting in 2017. A policy with a surrender value is reported to the policyholder's tax authority.VerifiedStates of Guernsey, CRS | Requires further review. Ireland's own CRS rules were not opened for this dataset. Under UK rules a cash value insurer is a Specified Insurance Company for CRS purposes.Requires further reviewIEIM400840 | Requires further review. The Isle of Man's own CRS rules were not opened for this dataset. Under UK rules a cash value insurer is a Specified Insurance Company for CRS purposes.Requires further reviewIEIM400840 | Requires further review. Jersey's own CRS rules were not opened for this dataset. Under UK rules a cash value insurer is a Specified Insurance Company for CRS purposes.Requires further reviewIEIM400840 | Requires further review for UK readers. Luxembourg CRS guidance covers cash value insurance; its detail was not rechecked for this dataset.Requires further reviewLuxembourg CRS guidance |
| US person in the family: IRC 4371 treaty route | Guernsey is not on the IRS list of treaties giving exemption from the US excise tax on premiums paid to foreign insurers, so there is no treaty route for a US person.VerifiedIRS, exemption from section 4371 excise tax | Ireland is on the IRS list of treaties with an exemption from the US excise tax on premiums. Relief needs an effective closing agreement between the IRS and the insurer; the listing alone does not establish it.VerifiedIRS, exemption from section 4371 excise tax | The Isle of Man is not on the IRS list of treaties giving exemption from the US excise tax on premiums paid to foreign insurers, so there is no treaty route for a US person.VerifiedIRS, exemption from section 4371 excise tax | Jersey is not on the IRS list of treaties giving exemption from the US excise tax on premiums paid to foreign insurers, so there is no treaty route for a US person.VerifiedIRS, exemption from section 4371 excise tax | Luxembourg is on the IRS list of treaties with an exemption from the US excise tax on insurance premiums (not reinsurance). Relief needs an effective closing agreement between the IRS and the insurer; the listing alone does not establish it.VerifiedIRS, exemption from section 4371 excise tax |
| Writing through a UK branch | Not researched. A policy written through a UK branch of a non-UK insurer is treated differently for the basic-rate credit (HS321) and possibly for the FSCS; whether insurers here write UK business through a UK branch has not been checked.Under researchHS321 (UK branch exception) | Not researched. A policy written through a UK branch of a non-UK insurer is treated differently for the basic-rate credit (HS321) and possibly for the FSCS; whether insurers here write UK business through a UK branch has not been checked.Under researchHS321 (UK branch exception) | Not researched. A policy written through a UK branch of a non-UK insurer is treated differently for the basic-rate credit (HS321) and possibly for the FSCS; whether insurers here write UK business through a UK branch has not been checked.Under researchHS321 (UK branch exception) | Not researched. A policy written through a UK branch of a non-UK insurer is treated differently for the basic-rate credit (HS321) and possibly for the FSCS; whether insurers here write UK business through a UK branch has not been checked.Under researchHS321 (UK branch exception) | Not researched. A policy written through a UK branch of a non-UK insurer is treated differently for the basic-rate credit (HS321) and possibly for the FSCS; whether insurers here write UK business through a UK branch has not been checked.Under researchHS321 (UK branch exception) |
| Main limits for a UK family | Protection is a trust over at least 90% of liabilities, not a compensation fund; how the trust operates on a failure has not been read in the trust deeds. UK tax, PPB and IHT treatment are exactly as for the other four.Requires further review | No compensation fund for life policies, and the governing law was not checked here. UK tax, PPB and IHT treatment are exactly as for the other four.Requires further review | The scheme pays up to 90%, not 100%, and only after an insurer fails; the governing statute was not read in the primary text. UK tax, PPB and IHT treatment are exactly as for the other four.Requires further review | What protects a policyholder if a Jersey insurer fails requires further review and is not assumed. UK tax, PPB and IHT treatment are exactly as for the other four.Requires further review | A priority claim over segregated assets is not a guarantee of value, and it does not widen what a UK resident may hold: the PPB rules still decide the investment menu. UK tax and IHT treatment are exactly as for the other four.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 basic-rate credit because the insurer has already paid tax on its fund (IPTM3810), and FSCS cover of 100% with no upper limit applies, for failures on or after 3 July 2015, where the failed insurer was regulated by the PRA (FSCS).
- 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 would be a foreign policy like the five above: same chargeable event rules, no basic-rate credit, same PPB rules, no FSCS.
- Bermuda policyholder protection and regulation have not been researched for UK readers, so the jurisdiction is not profiled here.
A UK branch of a non-UK insurer Not profiled
What is known. HMRC excludes a policy issued by the UK branch of a non-UK insurer from the foreign-policy rule on the basic-rate credit (HS321).
- Which insurers in the five jurisdictions write through a UK branch, and what that means for FSCS cover, has not been researched.
Methodology
What the three questions change, and why nothing is ranked.
What the tool does
It sets out, for your UK position, the rules that apply to a policy from each of the five insurers, and shows which facts about each domicile are verified. It calculates three illustrations at your amount: the first-year PPB charge if the policy were a personal portfolio bond, the inheritance tax exposure of a personally held policy, and, where a US person is in the family, the US excise tax on premiums.
What it does not do
It does not rank the five, because none of them changes a UK resident's tax. 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 trusts beyond naming who is taxed.
The three questions
Your UK residence position selects the rules that apply: long-term resident, arrived in the last 10 years, leaving the UK, or non-resident with UK heirs. The amount band supplies the premium used in the illustrations (the midpoint of a closed band; £10,000,000 for the open band). The US person answer adds the US excise question. Two optional refinements, how the investments are chosen and who holds the policy, change the warnings shown.
Status of a profile
Three fields decide whether a profile is described as checked: regulator, governing insurance law and failure protection. If any is not verified, the card says "requires further review" and names the gap. No field carries a score and no jurisdiction is placed above another.
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.
A is total premiums paid, B the total of earlier deemed gains, C the total of earlier part-surrender gains (ITTOIA s.522; HS321). Tax is the gain at your marginal savings rate, with no top-slicing relief and no basic-rate credit.
Adjusted for any gains already taxed on earlier part surrenders (HS321). The 5% withdrawals are brought back in here: they are deferred, not tax-free. Taxed as savings income at 20, 40 or 45% for 2026/27. Top-slicing relief divides the gain by the complete years (never less than 1) to find the rate.
A is the number of days of non-UK residence in the material interest period, B the total days (ITTOIA s.528). Individuals only.
For a personally held policy of a long-term UK resident, before the nil-rate band, reliefs and exemptions.
Shown only where a US person is in the family, and flagged as removable only with an effective IRS closing agreement for Ireland or Luxembourg.
Sources and authorities
Legislation, HMRC manuals and regulators, each with the date checked.
https://www.gfsc.gg/sites/default/files/Standard-Condition-for%20Life-Companies-(for-information-only).pdf Checked 23 September 2026
https://www.fscs.org.uk/what-we-cover/insurance/ Checked 23 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 23 September 2026
https://www.legislation.gov.uk/ukpga/2005/5/section/516 Checked 23 September 2026
https://www.legislation.gov.uk/ukpga/1988/1/section/552A Checked 23 September 2026
https://www.gov.uk/hmrc-internal-manuals/residence-and-fig-regime-manual/rfig45100 Checked 23 September 2026
https://www.legislation.gov.uk/ukpga/1984/51/section/6A Checked 23 September 2026
https://www.gov.gg/crs Checked 23 September 2026
https://www.irs.gov/businesses/international-businesses/exemption-from-section-4371-excise-tax Checked 23 September 2026
https://centralbank.ie/docs/default-source/Regulation/industry-market-sectors/insurance-reinsurance/solvency-ii/insurance-compensation-fund/gns-4-4-10-1-9---insurance-compensation-fund-ex-note.pdf Checked 23 September 2026
https://www.gov.uk/hmrc-internal-manuals/international-exchange-of-information/ieim400840 Checked 23 September 2026
https://www.iomfsa.im/consumer-material/compensation-scheme-life-assurance/ Checked 23 September 2026
https://www.legal500.com/guides/chapter/isle-of-man-insurance-reinsurance/ Checked 23 September 2026
https://www.jerseyfsc.org/industry/sectors/insurance/insurance-legislation/ Checked 23 September 2026
https://www.caa.lu/en/the-caa Checked 23 September 2026
https://www.caa.lu/uploads/documents/files/Law_on_the_insurance_sector_2015-12-07_consol_2026-04-03_ESAP_.pdf Checked 23 September 2026
https://impotsdirects.public.lu/fr/echanges_electroniques/CRS_NCD.html Checked 23 September 2026
https://www.gov.uk/hmrc-internal-manuals/insurance-policyholder-taxation-manual/iptm3720 Checked 23 September 2026
https://www.gov.uk/hmrc-internal-manuals/insurance-policyholder-taxation-manual/iptm3650 Checked 23 September 2026
https://www.gov.uk/hmrc-internal-manuals/insurance-policyholder-taxation-manual/iptm3210 Checked 23 September 2026
https://www.gov.uk/hmrc-internal-manuals/insurance-policyholder-taxation-manual/iptm3734 Checked 23 September 2026
https://www.gov.uk/hmrc-internal-manuals/insurance-policyholder-taxation-manual/iptm7730 Checked 23 September 2026
https://www.legislation.gov.uk/ukpga/2005/5/section/520 Checked 23 September 2026
https://www.legislation.gov.uk/ukpga/2005/5/section/528 Checked 23 September 2026
https://www.gov.uk/income-tax-rates Checked 23 September 2026
https://www.luxembourgforfinance.com/en/financial-centre/insurance/ Checked 23 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.
- 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 unless a later date is stated. 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
- 23 September 2026
- Dataset
- 2026.09.23-uk
- Methodology
- 1.0.0-uk
- Engine
- 1.0.0-uk
- Review status
- No independent professional sign-off
- 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.