client invested £50,000 in offshore life assurance bond in 2008, surrendered in 2019 for £35,000. No withdrawals made at anytime. Is the loss of £15,000 available as deficiency relief to set off against income subject to HRT. I am confused by the calculation which suggests any loss is restricted to the lower of the loss or gains on previous withdrawals. As there has been no previous gains, then is the deficiency restricted to Nil?