Husband who is a 50% tax payer owns an investment bond which he switches to his non taxpaying wife who then surrenders the bond at a gain. Clearly this transaction is done to benefit from the wife’s lower tax rates. But would HMRC really deem the husband still the beneficial owner and tax him instead?
In all my years I haven’t seen HMRC do this and this has been deemed sensible family tax planning. However, a number of third parties are now strongly suggesting this is wrong.