A chargeable event gain may have accrued over a number of years but falls to be treated as income of one particular tax year (in which the chargeable event occurs). This could have had the effect of charging tax on some part of the gain at a higher rate than would otherwise have been the case if the gain had been treated as accruing evenly over the policy period. ‘Top-slicing relief’ was introduced as a means of alleviating that position.

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