Gifting as part of normal expenditure out of income

Technical Services Gifting as part of normal expenditure out of income Gifting For professional advisers only

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Contents Explanatory note for gifting as normal expenditure out of income 4 Record keeping and reporting requirements 6 Gifts out of normal expenditure enhanced calculator 8 HMRC form Gifts made as part of normal expenditure out of income (IHT403) 9 Extracts from HMRC manual 10 Canada Life s products that can be used with normal expenditure out of income 17 3

Explanatory note for gifting as normal expenditure out of income Section 21 Inheritance Tax Act (IHTA) 1984 exempts a transfer if, taking one year with another, it can be shown that it was made out of surplus income and that, after the gift, the transferor had sufficient net income to keep up his usual standard of living. In other words this is not a way of making gifts out of capital. These rules were considered in Bennett and others v IRC (1995). In this case the court identified several points to consider: normal expenditure means that which, when it took place, was part of the settled pattern of expenditure adopted by the donor; a settled pattern can be shown from the expenditure of the donor over a period of time or by showing that the donor assumed a commitment or adopted a firm resolution, in relation to future expenditure and has then made gifts in accordance with that commitment; there is no fixed minimum period to establish the relief; where there is no formal commitment or resolution, it may be necessary to show a series of payments (three will usually suffice, two possibly); there can be some variation in the pattern, but to claim the relief it must be shown that the donor intended a pattern to exist and to remain for a period of time (barring unforeseen circumstances); the amount of the transfer does not have to be fixed; the amount need not be to the same person each time; the amount may be fixed by a formula such as a percentage of earnings or a figure such as what is left over after paying nursing home fees ; tax planning does not disqualify the expenditure: almost the reverse; if the taxpayer can show that he/she entered into a series of gifts having taken advice, and intending to make use of the relief in s.21 IHTA 1984, it will help that he/she took the advice in claiming the relief. HM Revenue & Customs (HMRC) interpret income as meaning income net of tax and normal outgoings. The relief is a valuable one which is often overlooked when undertaking tax planning. It is essential that evidence of such payments is collected and retained which will enable any claim for this relief to be substantiated. HMRC outline their approach to calculating the net income in form IHT403 (see page 9). 4

Where is the relief beneficial? The relief does not disturb any other exemptions, nor does it constitute a chargeable transfer and can be used to prevent an inheritance tax (IHT) problem arising. It can therefore be very useful when making regular contributions into a policy written into trust. Canada Life can assist you in choosing an appropriate trust to suit the needs of both the settlor (the person making such gifts), and the intended beneficiaries. The Canada Life products that can be used when considering this type of planning can be found on page 17 of this booklet. 5

Record keeping and reporting requirements Evidence should be kept to support a claim for this exemption. Examples of the information that needs to be collected can be found on pages 8 and 9. Regulations were introduced in February 2008 concerning lifetime reporting of gifts under this exemption on form IHT100. Before this, such gifts only needed to be reported on death. The requirements for both lifetime and death reporting are outlined below. If you have any queries, please contact your Canada Life representative. Lifetime gifts In order to determine whether a report is required, the donor needs to add together any gifts made under this exemption in the preceding seven years with any chargeable lifetime transfers made in the same seven year period. If the total exceeds the donor s nil rate band, a report is required using form IHT100. HMRC will review the exemption at this time to confirm it meets the requirements and confirm their conclusion in writing. The HMRC Inheritance Tax Manual sets out its approach to such claims and more detail can be found on the HMRC website. Relevant extracts from the IHT manual can be found on pages 10 to 17 of this booklet. Reports on death The executors of the deceased s estate will need to include a claim that gifts should be treated as exempt as gifts out of income on forms IHT400 and IHT403. The form IHT403 incorporates a schedule which may be used to substantiate the claims to this relief. An extract from form IHT403 is enclosed on page 9 together with an enhanced version prepared by Canada Life on page 8. The enhanced form does not replace form IHT403 but allows a more detailed record to be kept. It is essential that adequate records are kept and maintained on a regular basis and these forms should be completed at least yearly as part of a continuing review of the donor s circumstances. 6

Excepted Estates The executors of excepted estates do not have to deliver a full account to HMRC after the death of a taxpayer. These estates are either low value, where the gross value is worth less than the nil rate band (or, in certain circumstances, twice the nil rate band) or exempt excepted estates where, broadly, the gross value is less than 1m and there is no IHT liability once the spouse and/or charity exemption is taken into account. These limits apply to deaths occurring on or after 1 March 2011. An estate cannot be an excepted estate if specified transfers made by the deceased in the seven years before death exceed 150,000. These are chargeable transfers (or failed PETs) which are comprised of quoted shares or securities. Before 1 March 2011, there was no limit on the amount of gifts qualifying under the gifts out of normal expenditure exemption that excepted estates could claim when applying the above limits. For deaths on or after 1 March 2011, however, where surplus income gifts exceed 3,000 in any tax year in the seven years before death, these will be deemed to be chargeable transfers when determining whether any of the above limits have been exceeded. This means that, even though the transfers may be exempt, HMRC may now review claims more closely because they felt the exemption was being used inappropriately with IHT not being paid when due. 7

Gifts out of normal expenditure enhanced calculator Tax year Income Salary Investment income Rental income State pension Other pensions Gross income less tax paid Net income (A) 1 2 3 4 5 6 7 Tax year Expenditure Pension contributions Mortgage Gas Electric Telephone Water rates Council tax Car tax Car insurance Nursing home fees School/nursery fees Household expenses Other bills Total expenditure (B) 1 2 3 4 5 6 7 Surplus income (A-B) Gifts (deficit) made Your name Your address (including postcode) Date completed / / 8

Extract from HMRC IHT403 9

Extracts from HMRC manual (January 2018) IHTM14241 Conditions for normal out of income exemption: Normal expenditure The dictionary definition of normal includes standard, regular, typical, habitual or usual. For the purpose of this exemption, normal means normal for the transferor and not for the average person. In most cases, it will be clear whether or not there is a pattern of giving, but it is not always that simple. It is possible that a number of gifts made by one person may not qualify. It is also possible for a single gift to qualify if it is or is intended to be the first of a pattern and there is evidence of this. You will need to analyse all the facts in cases of doubt to see if a pattern can be found (IHTM14242). Factors to take into account in looking at any pattern of gifts include the frequency and amounts, the nature of the gifts, the identity of the donees and the reasons for the gifts (IHTM14243). IHTM14242 Conditions for normal out of income exemption: pattern of gifts Some cases present a complex picture with regular gifts, one-off gifts, capital gifts and different interwoven habits. You will need to analyse these cases carefully to determine whether a pattern, or patterns, exists and which gifts form part of which pattern. You must leave out of consideration any gift clearly made for some special purpose. There is no set time span over which the taxpayer must show the pattern of giving. A reasonable span would normally be three to four years. However, you can consider a longer period if this helps the taxpayer to illustrate the gifts were normal (IHTM14243). A pattern is more difficult to identify where a single gift is involved particularly if this is made close to the date of death. The taxpayer or agent must provide strong evidence in such cases that the gift was genuinely intended to be the first in a pattern and that there was a realistic expectation that further payments would be made. If a single gift is also said to be made from accumulated income rather than the available income of the year in which it was made you should refer the case to [HMRC] Technical. A single gift by way of payment under a deed of covenant or other regular commitment, such as payment of the first of a series of premiums on a life policy may be accepted as normal. On the other hand there may be an indication that the gifts were never intended to continue from the outset. For example: Some life policies provide that after payment of the first premium the policy may be converted into a fully paid one. A policy may also be taken out when the transferor s expectation of life was very short. In either of these cases, any gifts could not be regarded as normal expenditure. Lifetime cases In rare cases, the exemption may need to be discussed during the transferor s lifetime, for example where a gift is made into trust and would be an immediately chargeable lifetime transfer if the exemption was not available. If, within the principles outlined above, the taxpayer asserts that a first gift is part of an intended series, you can allow the exemption provisionally in the first instance. Make it clear that HMRC proposes to review (and if appropriate disallow) the exemption by reference to the transferor s future gifts if any. 10

Example In the four years before his death, Peter made gifts from his income of 1,000 to each of his three children on their respective birthdays and 500 to each child at Christmas. He also paid regular monthly premiums of 100 into a life policy written in trust for the benefit of his wife. In the same period, he gave his eldest child 20,000 to pay off her debts and gifted 5000 shares, representing a 50% interest in a company, to his sister who already held the other 50% interest. The birthday and Christmas gifts form a pattern of giving as do the life policy premiums, so these are exempt. The one-off gift of cash to the eldest child is not exempt as it does not fall within a pattern. The gift of shares is not exempt as it is a gift of a capital asset and also not part of a pattern of giving. IHTM14243 Conditions for normal out of income exemption: Factors to consider You must test whether a gift is normal by considering all the relevant factors. These will include the frequency and amount, the nature of the gifts, the identity of those who received them and the reasons for the gifts. Frequency Normal does not necessarily mean regular or annual/yearly although gifts made on a regular basis are more likely to meet the normality test. In many cases averaging the yearly amount of the transferor s gifts of a particular type will help to form a fair opinion. Amount The amount of the gift is an important factor. The gifts must be comparable in size although you do not need to query small differences. Sometimes, gifts may be made by reference to a source of income that is by its nature variable in amount, for example annual dividends from company shares. Similarly, gifts may relate to specific costs such as grandchildren s school fees which may also vary in amount. If a particular gift is in a different category from those which are normal because of its size, further evidence will be needed to see if and how it fits in with the normal pattern. In some cases an unusually high figure may be treated as including an amount that would be normal. The part of the gift that is treated as normal will be exempt and the remaining amount, above the normal part, will not qualify for the exemption. Nature of the gifts Lifetime gifts from income will usually be made as transfers of money either directly to the donee or as payments made on their behalf, for example, mortgage payments. Gifts from capital or gifts of capital assets fall outside the exemption. But a capital asset could be purchased out of income specifically for the donee. In this case, the gift may fall within a normal pattern of giving if the nature of the gift is comparable with other gifts made. For example a gift of a car may be comparable to a gift of jewellery of a similar value. On the other hand personal goods, cash, securities, or a share in a business might not be comparable to one another. Identity of donees Gifts made to donees in the same category can usually, but not always, be considered together, for example, birthday gifts to grandchildren. However, gifts made will often fall into different categories such as gifts to family on the one hand and gifts to charitable organisations on the other. A proven habit of making gifts of one sort has no apparent bearing on the question of whether gifts of the other kind were normal. But provided that the gifts in question belong to one category, it does not matter that the individual recipients may have varied. 11

Reasons for the gifts The circumstances around the gifts made and the reasons for them may indicate whether the transferor has habitually made gifts in such circumstances. The reasons may also be relevant in identifying the category of donee. For example, if the transferor habitually made gifts to persons in need, this might include relatives, other people and charitable organisations. But gifts to members of the same category are not always comparable. For example, a gift to set a son up in business would not be comparable to modest birthday gifts to children. IHTM14244 Conditions for normal out of income exemption: Case Law - Bennett v IRC The case of Bennett and others v Inland Revenue Commissioners [1995] STC 54 involved consideration of the first condition (IHTM14231) for exemption that the gifts made should form part of the normal expenditure of the transferor. The judge s view (Lightman J) was that the term normal in this context: connotes expenditure which at the time it took place accorded with the settled pattern of expenditure adopted by the transferor. He considered that the existence of the settled pattern could be established in two ways: an examination of the transferor s expenditure over a period of time may reveal a pattern, for example a payment each year of 10% of all income to charity or members of the individual s family, or the individual may be shown to have assumed a commitment, or adopted a firm resolution, regarding their future expenditure and then complied with it. The commitment may be legal, religious or moral. The commitment or resolution need have none of these characteristics but may still be effective to establish a pattern, for example, to pay the yearly premiums on a life assurance policy gifted to a third party or to give a pre-determined part of one s income to one s children. Before turning to the facts of the case, the judge summed up the requirement for expenditure to be normal: What is necessary and sufficient is that the evidence should manifest the substantial conformity of each payment with an established pattern of expenditure by the individual concerned a pattern established by proof of the existence of a prior commitment or resolution or by reference only to a sequence of payments. Refer any challenge to this view, or to the way the IHTA84/S21 legislation has been applied, to [HMRC] Technical. IHTM14250 Conditions for normal out of income exemption: out of income The second condition (IHTM14231) for exemption is that the transferor should have made the gift out of their income. So a gift of capital assets such as jewellery or securities does not qualify unless it was specifically purchased by the donor from income with the intention of making the gift. Income is not defined in the IHTA84 but should be determined for each year in accordance with normal accountancy rules. It is not necessarily the same as income for income tax purposes. Income is the net income after payment of income tax. 12

It is usually clear whether payments received are income in nature. Common sources of income are employment and self-employment, rents from property, pensions, interest and dividends. But, it is possible that payments received on a regular basis may appear to be income but are in fact capital in nature. An example would be receipts from a discounted gift scheme (IHTM20424). Available income You should initially look at the income of the year in which gifts were made to see if there was enough income available to make the gifts, before considering earlier years. Income from earlier years does not retain its character as income indefinitely. At some point it becomes capital but there are no hard and fast rules about when this point is. If there is no evidence to the contrary, we consider that income becomes capital after a period of two years. Evidence to the contrary could impact either way as income: may immediately be invested in a capital product and become capital or may be retained as income for more than two years with a specific purpose in mind. Each case will depend on its own facts but, in general, the longer the period of accumulation, the more likely it is that the income has become capital. However, this is not the only factor to consider. You will also need to look at how the accumulation has been made and the transferor s actions (or inaction) in accumulating it. Often the taxpayer will try and claim that the exemption applies on gifts made out of several years of accumulated income, which you should deny. But this is a contentious area and you should seek the advice of [HMRC] Technical before becoming entrenched. If a gift is made out of a current account you only need to check that the gift could have been made out of income. You do not need to match the gift to specific money in the account. Annuities The capital element of a purchased life annuity within the meaning of ITTOIA 2005/S423 (IHTM20631) purchased on or after 13 November 1974 is not regarded as part of the transferor s income for the purposes of the exemption in accordance with IHTA84/S21(3). Insurance policies A person may receive payments from insurance policies in a number of situations; on maturity, by full or part surrender of a policy, by regular withdrawals, by sale, assignment or loan. Some of these payments are chargeable to income tax but that does not make them income. Even if the payments are regular, the character of such payments is usually capital and they cannot be taken into account in calculating the income available to a transferor. A common situation is where a person takes annual withdrawals equal to 5% of the premium from a single premium policy. If the taxpayer or agent argues that payments of this sort are income in nature, you should obtain all the relevant documents and refer the case to [HMRC] Technical. Fluctuating income The intention in including taking one year with another in IHTA 1984/S21(1)(b) is to provide for the case where a person s income fluctuates from year to year but overall they have enough income to make normal gifts and meet their standard of living on an ongoing basis. In these cases, you may need to look at the income and expenditure over a number of years to see if the income test is satisfied. Although income can be carried over from year to year in these circumstances, you should refer to [HMRC] Technical if the taxpayer wishes to carry forward more than two year s income. 13

If there is a permanent change in the transferor s level of income or expenditure, for example they start having to pay for care home fees, you should use your judgment in accepting or refusing the exemption in full or in part for continuing regular gifts. Lifetime care plans It is becoming increasingly popular for individuals to provide for the expense of nursing or residential care by purchasing a specially designed plan. These plans, which may be described as lifetime care plans or immediate care plans, are purchased with a single capital payment, in return for which the plan provider pays the care fees direct to the nursing home on a periodic basis. Our view is that the payments by the plan provider are not income for the purposes of IHTA84/S21 (1)(c) but are effectively a return of part of the capital originally provided by the purchaser. However, the nursing home fees are part of the deceased s normal expenditure. If the taxpayer claims that part of the payment represents income produced by the unused part of the premium while it is held by the plan provider, you should obtain the following before referring the case to [HMRC] Technical: a copy of the plan, details of the original premium, details of the payments made by the plan provider. IHTM14251 Conditions for normal out of income exemption: Case Law - McDowell The case of McDowell and others (executors of McDowell, deceased) v Commissioners of Inland Revenue and related appeal [2004] STC(SCD) 22 is the only case to date that has considered the second condition that a gift is made out of income. The gifts in question were made under a power of attorney and the first set of appeals was unsuccessful because it was held that the attorney had no power to make the gifts. The Special Commissioners though made a decision in principle on the second set of appeals that the gifts, if validly made, would have been normal expenditure out of income. The deceased s Attorney had made five payments of 12,000 to each of the deceased s five children from the deceased s current account. It would appear that the money had been accumulated in a deposit account over a period of about three years before its transfer into the current account. The Special Commissioners concluded that the gifts were made out of income and that they were exempt under IHTA84/S21. This turned on their view that it was identifiably money which was essentially unspent income and not invested in any more formal sense. It was also important that the Attorney had considered the matter and had taken the view that the payments were being made out of income. Other gifts had also been made but were not regarded as gifts out of income. The Special Commissioners did not consider the meaning of the words taking one year with another in IHTA84/S21(1)(b); nor did they offer any general guidance on when accumulated income becomes capital. It is significant though that they did not consider that the duration of accumulation was, by itself, a decisive consideration. They considered it more important to look at how and for what purpose the income had been accumulated. You may see the argument that McDowell provides authority that all income that has not been formally invested retains its character as income indefinitely but that is not what the case established and you should resist any such argument. 14

Evidence was available in this case from the Attorney himself but, in most cases, the gifts in question will have been made by a deceased person and you will need to look for evidence of intention from other sources. You should not accept the taxpayer stating that income was being accumulated with the intention of making a gift out of that income without supporting evidence. Although this case primarily involved the condition for exemption in IHTA84/S21(1)(b), the Special Commissioners also followed the principles established by Lightman J in the Bennett case (IHTM14244) regarding normal expenditure. In our view, the pattern of payments of small gifts at birthdays and Christmas is readily distinguishable from the larger payments of 12,000 and can provide no support for establishing a pattern of payment of larger sums; nor do we consider that the deceased s habit of making gifts, including those disguised as loans, on sporadic occasions of need can help the appellants. However, we consider that the evidence is just sufficient to enable us to conclude that Mr McNeill, as attorney, made a commitment regarding future expenditure, namely to distribute a substantial part of the excess of WCM s income over the amount required for his maintenance (making due allowance for unforeseen circumstances) equally among WCM s five children. The payments of 12,000 to each of the five children in 1997 demonstrated that the commitment was being implemented, and we are satisfied from his evidence that, but for WCM s death, Mr McNeill would have continued to make similar, even if much smaller, payments. IHTM14255 Conditions for normal out of income exemption: transferor s standard of living The third condition (IHTM14231) for exemption contained in IHTA84/S21(1)(c) is that, after allowing for all gifts forming part of their normal expenditure, the transferor must have been left with enough income to maintain their usual standard of living. Gifts, even if made out of income, will not qualify for exemption if the transferor had to resort to capital to meet their normal living expenses. You may find it useful to consider this third condition alongside the second requiring the gift to be made out of income. To decide if the exemption applies, you need to establish: whether the transferor could meet their normal living expenses from their income after reducing it by the transfers in question, in that year, and if not, if they could do so by taking one year with another In practice, you should consider what is current income and expenditure on an annual basis using the accounting year to 5 April. However, if the taxpayer requests a longer period than a year to be considered, because for example the transferor had saved surplus income from previous years in order to make the gifts, you must consider the case on its merits. You should ignore gifts that are not part of the transferor s normal expenditure and test the condition as if such abnormal gifts have never been made. 15

Sufficient income Although the normal expenditure gifts must have left the transferor with sufficient income to maintain their usual standard of living, they do not need to have actually used this for living expenses. The transferor may in fact choose to use capital to meet their living expenses and use the income remaining, after making the gifts, for some other purpose. It is enough, for the exemption to apply, that the income was enough to meet both the normal expenditure gifts and the usual living expenses. If the income that is left after making the gifts is not enough to meet the usual living expenses, the exemption is not available in full, but part of the gifts may still qualify for the exemption. Usual standard The usual standard of living will generally be what was usual for that transferor at the time the transfer was made. If the transferor has had to lower their standard of living for some other reason, such as losing their job or a drop in income on retirement, the exemption may not be completely lost if they had made a regular commitment at an earlier date when surplus income was available. For example, the transferor may have taken on a commitment to pay regular insurance premiums, initially affordable out of income, but later on has to pay nursing home fees, that were unforeseen when the policy was first taken out. But, a commitment made at a time when the fall in income could be foreseen would not qualify. IHTM06106 Excepted transfers and terminations operation of the regulations with normal expenditure out of income exemption A chargeable transfer (IHTM04027) is a transfer of value (IHTM04024) which is not an exempt transfer (IHTM04026). Thus, if a transfer of value is wholly covered by an exemption, it is an exempt transfer and does not need to be reported. This can easily be determined in the case of the annual exemption (IHTM14141) or other unconditional exemptions; but the position is not so straightforward in the case of the normal expenditure out of income exemption (IHTM14231) where the exemption is only available.to the extent that it is shown that the exemption applies. And we interpret shown as meaning shown to the satisfaction of HMRC. It follows therefore that where normal expenditure out of income exemption is in point, a transfer of value remains a chargeable transfer unless and until it is shown to be exempt. This requirement to show that the exemption is available may suggest that it is necessary to deliver an account in all cases so that the exemption may be agreed. This will defeat the purpose of the regulations. You should therefore adopt the position below. Where denial of the exemption would not breach the limits for a cash transfer (IHTM06103), there is no need for an account to be delivered. We will consider whether the exemption is due if and when the matter is material when a later transfer is made or on death. Where denial of the exemption either in respect of a single gift (whether it is the first of a planned series of gifts or a gift within a series) or cumulatively taking into account earlier transfers would mean that there is a liability to IHT, an account should be delivered so that the availability of the exemption can be agreed. 16

Example The transferor makes a number of gifts of 50,000 cash each year to the trustees of a relevant property trust which they consider qualifies for exemption as normal expenditure out of income. No other exemptions are available and no other transfers made. No account will be necessary until the cumulative total of the value transferred by all the transfers of value exceeds the nil rate band which at current levels would mean not until the seventh transfer is made. Example The transferor makes a transfer of land into trust valued at 200,000, and they then transfer 25,000 cash each year for three years into the trust which they consider qualifies for exemption as normal expenditure out of income, followed by another transfer of land of 40,000. No other exemptions are available. With a nil rate band at 300,000 [now 325,000], if the cash transfers are exempt as normal expenditure out of income, the second transfer of land will be an excepted transfer as the cumulative total of chargeable transfers does not exceed 80% of the nil rate band. If they are not exempt (and therefore chargeable) they themselves would qualify as excepted transfers (being transfers of cash with a cumulative total of chargeable transfers below the nil rate band); but the nil rate band left available to the transferor at the time of the second transfer of land would only be 25,000. As the transfer of value exceeds this (IHTM06104) an account should be delivered for the transfer of land and that account should make reference to all the earlier transfers so the position can be agreed. This document is based on Canada Life Limited s understanding of applicable legislation, law and current HM Revenue & Customs practice as at January 2018. It is provided solely for general consideration. The information regarding taxation is based on our understanding of current legislation, which may be altered and depends upon the individual financial circumstances of the investor. We recommend that investors seek their own independent tax advice. Canada Life products that can be used with Normal Expenditure Out of Income exemption Detailed below are products that can be used in conjunction with this exemption. More information on each of these can be found on our website, canadalife.co.uk International Products Investment Offshore Savings Account Premiere Account Premiere Europe Account Protection Flexible Life Plan CanProtect Whole of Life 17

About Canada Life Canada Life Limited provides insurance and wealth management products and services through domestic operations in Canada and international operations in the Republic of Ireland, Isle of Man, Germany and the U.K., as well as branch and subsidiary operations in other countries. Canada Life is a subsidiary of The Great-West Life Assurance Company and a member of the Power Financial Corporation group of companies. www.canadalife.co.uk/adviser Delivering accessible Technical Services A dedicated national sales team allowing direct access to industry specialists with more than 200 years of experience in taxation, trusts, estate planning and pensions between them. Technical information delivered personally to you by experts, in the right way at the right time, for both UK and international investment business. Call your local account manager first to find out more. Additional support is available from: Technical Services: 01707 422999 ican@canadalife.co.uk www.canadalife.co.uk/ican 18

Make sure my client s wealth stays in the right hands Keeping Client Wealth in the Family for 40 years Canada Life International provides award-winning, robust estate planning solutions delivered with absolute dedication to the UK market. When it comes to estate planning and mitigating the effects of IHT, our Wealth Preservation Accounts offer your clients unrivalled flexibility, whatever their current and future financial needs. And, with these solutions offered through both the Isle of Man and Ireland, your clients naturally get all the benefits of working with an international provider at home. Call your local account manager for more information, or contact our Technical Services team on 01707 422999 or ican@canadalife.co.uk www.canadalife.co.uk/international Wealth Preservation Accounts Canada Life Limited, registered in England no. 973271. Registered office: Canada Life Place, Potters Bar, Hertfordshire EN6 5BA. Telephone: 0345 6060708 Fax: 01707 646088 www.canadalife.co.uk Member of the Association of British Insurers. Canada Life International Limited, registered in the Isle of Man no. 33178. Registered office: Canada Life House, Isle of Man Business Park, Douglas, Isle of Man IM2 2QJ. Tel: +44 (0) 1624 820200 www.canadalifeint.com Canada Life International Assurance (Ireland) DAC, registered in Ireland no. 440141. Registered office: Irish Life Centre, Lower Abbey Street, Dublin 1, Ireland. www.canadalife.co.uk/international Canada Life Limited is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. Canada Life International Limited and CLI Institutional Limited are Isle of Man registered companies authorised and regulated by the Isle of Man Financial Services Authority. Canada Life International Assurance (Ireland) DAC is authorised and regulated by the Central Bank of Ireland. MAR01364 1117R

Canada Life Limited, registered in England no. 973271. Registered office: Canada Life Place, Potters Bar, Hertfordshire EN6 5BA. Telephone: 0345 6060708 Fax: 01707 646088 www.canadalife.co.uk Member of the Association of British Insurers. Canada Life International Limited, registered in the Isle of Man no. 33178. Registered office: Canada Life House, Isle of Man Business Park, Douglas, Isle of Man IM2 2QJ. Telephone: +44 (0) 1624 820200 Fax: +44 (0) 1624 820201 www.canadalifeint.com Member of the Association of International Life Offices. Canada Life Limited is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. Canada Life International Limited and CLI Institutional Limited are Isle of Man registered companies authorised and regulated by the Isle of Man Financial Services Authority. MKT450 218R