Top slicing relief
6 April 2024
Key points
- HMRC guidance is the only reliable way of calculating top slicing relief
- The same method can be used for both onshore and offshore bonds
Jump to the following sections of this guide:
- What is top slicing relief?
- Calculation basics
- Example scenarios
- Example 1 - Full gain plus other income over higher rate threshold, top slice gain plus other income below higher rate threshold
- Example 2 - Full gain and top slice gain straddle higher rate threshold
- Example 3 - Bond gain and sliced gain above the higher rate threshold, and reduced personal allowance
What is top slicing relief?
The taxation of investment bonds is unique. Bonds offer investors tax deferral on investment growth until there is a chargeable gain.
However, when a 'chargeable event' does occur, the whole gain will be taxed in that tax year. As a result, more of the gain could be taxed at higher rates than if it had been taxed on an annual basis. 'Top slice relief' attempts to correct this by providing a deduction from the amount of tax due.
This guide explains, with examples, the impact of a chargeable event on the total tax bill, how to calculate the amount of top slice relief, and how much tax there is on the bond itself. It is based on current HMRC guidance.
Calculation basics
These can be broken down into three main steps:
1. Work out the total tax liability before top slice relief (by including the full bond gains)
Before working out the tax, work out the value of allowances to be used in the calculation, specifically the personal allowance, the starting rate band for savings and the personal savings allowance.
Then it is simply a case of taxing income in the right order using unused allowances and the tax bands:
Order of income for tax:
- Non-savings income (inc. salary, pension, profits from trade, rent)
- Savings income (inc. interest and offshore bond gains)
- Dividends
- Onshore bond gains
2. Work out the amount of top slicing relief
Broadly, this is the difference between the tax paid on the full gain, less the tax paid on the average gain (or 'slices').
There are three additional things to note.
Firstly, the order of income for calculating top slicing relief changes, so that both offshore and onshore bond gains are taxed after all other income.
Secondly, because top slicing is essentially to relieve tax paid at higher rates, an amount known as 'tax treated as paid' is deducted. This applies to both onshore and offshore bonds, and will usually be 20% of the whole gain or average gain (depending on which calculation you are dealing with).
However, if any unused personal allowance is available against the bond gain the tax treated as paid will be 20% of the gain after deducting the personal allowance used against the gain.
Example
Jack has a pension of £10,570 and a bond gain of £80,000 made over 8 years. On the full gain calculation, the tax treated as paid will be (£80,000 - £2,000) x 20% = £15,600. On the average gain calculation, it will be (£10,000 - £2,000) x 20% = £1,600. If there had been no unused personal allowance, the tax treated as paid would have been £16,000 and £2,000 respectively.
Finally, the full gain is used to determine the total tax liability (step 1 in our examples) and the total tax on the full bond gain (step 2a).
The sliced gain is added to total income to determine availability of the personal allowance and personal savings allowance in the calculation of tax on the slice (step 2b).
For gains made prior to 2018/19 the full gain was used to determine eligibility to personal allowance in step 2b of the calculation 'the tax on the slices' . The full gain was also used to determine the amount of personal savings allowance in step 2b, for gains made before 6 April 2021.
3. Deduct the top slice relief from (1) to arrive at the tax due
Having worked out the figure for top slice relief, deduct it from the total liability calculated in step 1 to arrive at the tax due.
Finally, if the bond is onshore, the tax treated as paid figure for the whole gain can also be deducted, but no part of this can be reclaimed from HMRC if it is greater than the tax due.
Example scenarios
Following these principles, the examples below, based in the 2024/25 tax year, show how top slicing works in different scenarios.
Example 1 - Full gain plus other income over higher rate threshold, top slice gain plus other income below higher rate threshold
Joe has the following income chargeable to tax:
- Salary = £25,270
- Interest = £500
- Offshore bond gain = £60,000 over 10 years
He will therefore be entitled to the following allowances:
- Personal allowance (PA) of £12,570 (because 'adjusted net income' is below the £100,000 income limit)
- Starting rate band for savings (SRBS) of zero (because non savings income, in this case the salary, is greater than the sum of the PA and £5,000)
- Personal savings allowance (PSA) of £500 (because he has income taxable at the higher rate). However, for the purpose of calculating the tax on the slices in step 2b his income is below the higher rate threshold and will therefore benefit from a PSA of £1,000 in that part of the calculation.
Step 1 - Total tax liability
Income | Calculation | Tax | |
Salary | £12,570 | Personal allowance @ 0% | £0 |
Salary | £12,700 | Basic rate @ 20% | £2,540 |
Interest | £500 | Personal savings allowance @ 0% | £0 |
Bond gain | £24,500 | Basic rate @ 20% | £4,900 |
Bond gain | £35,500 | Higher rate @40% | £14,200 |
Total tax | £21,640 |
Note that although the interest is within the PSA and taxed at 0%, it still uses up part on the basic rate band.
Step 2 - Top slicing relief
Step 2a - Total tax on full bond gain
Income | Calculation | Tax | |
Salary | £12,570 | Personal allowance @ 0% | N/A |
Salary | £12,700 | Basic rate @ 20% | N/A |
Interest | £500 | Personal savings allowance @ 0% | N/A |
Bond gain | £24,500 | Basic rate @ 20% | £4,900 |
Bond gain | £35,500 | Higher rate @40% | £14,200 |
Tax treated as paid | £60,000 @ 20% | (£12,000) | |
Tax on bond (2a) | £7,100 |
Step 2b - Tax on the slices, or 'relieved liability'.
The slice is £60,000/10 = £6,000
Income | Calculation | Tax | |
Salary | £12,570 | Personal allowance @ 0% | N/A |
Salary | £12,700 | Basic rate @ 20% | N/A |
Interest | £500 | Personal savings allowance @ 0% | N/A |
Bond gain | £500 | Personal savings allowance @ 0% | N/A |
Bond gain | £5,500 | Basic rate @ 20% | £1,100 |
Tax treated as paid | £6,000 @ 20% | (£1,200) | |
Tax on bond (2b) | £0 |
Top slice relief (2a -2b) = £7,100
Step 3 - Deduct the relief from the full tax liability
Income | Calculation | Tax | |
Salary | £12,570 | Personal allowance @ 0% | £0 |
Salary | £12,700 | Basic rate @ 20% | £2,540 |
Interest | £500 | Personal savings allowance @ 0% | £0 |
Bond gain | £24,500 | Basic rate @ 20% | £4,900 |
Bond gain | £35,500 | Higher rate @40% | £14,200 |
Total tax | £21,640 | ||
Top slicing relief | (7,100) | ||
Tax due | £14,540 |
From this we can see that the tax paid on the bond only is £4,900 + £14,200 - £7,100 = £12,000.
Top slice relief has effectively wiped out the higher rate liability on the bond gain (i.e. the whole gain taxed at 20% = £12,000).
Had the bond been an onshore bond, tax treated as paid of £12,000 could also have been deducted, and there would have been no further tax to pay on the bond as a result of the chargeable event.
Example 2 - Full gain and top slice gain straddle higher rate threshold
Jess has the following income chargeable to tax:
- Salary = £45,270
- Interest = £200
- Offshore bond gain = £30,000 over 6 years
- Dividends = £2,500
She will therefore be entitled to the following allowances:
- Personal allowance (PA) of £12,570
- Starting rate band for savings (SRBS) of zero
- Personal savings allowance (PSA) of £500
- Dividend allowance of £500
Income | Calculation | Tax | |
Salary | £12,570 | Personal allowance @ 0% | £0 |
Salary | £32,700 | Basic rate @ 20% | £6,540 |
Interest | £200 | Personal savings allowance @ 0% | £0 |
Bond gain | £300 | Personal savings allowance @ 0% | £0 |
Bond gain | £4,500 | Basic rate @ 20% | £900 |
Bond gain | £25,200 | Higher rate @ 40% | £10,080 |
Dividends | £500 | Dividend allowance @ 0% | £0 |
Dividends | £2,000 | Dividend higher rate @ 33.75% | £675 |
Total tax | £18,195 |
Step 2 - Top slicing relief
Remember in this step, the order of income changes so that the offshore bond gain is taxed as the highest part of income.
Step 2a - Total tax on full bond gain
Income | Calculation | Tax | |
Salary | £12,570 | Personal allowance @ 0% | N/A |
Salary | £32,700 | Basic rate @ 20% | N/A |
Interest | £200 | Personal savings allowance @ 0% | N/A |
Dividends | £500 | Dividend allowance @ 0% | N/A |
Dividends | £2,000 | Dividend higher rate @ 8.75% | N/A |
Bond gain | £300 | Personal savings allowance @ 0% | £0 |
Bond gain | £2,000 | Basic rate @ 20% | £400 |
Bond gain | £27,700 | Higher rate | £11,080 |
Tax treated as paid | £30,000 @ 20% | (£6,000) | |
Tax on bond (2a) | £5,480 |
Step 2b - Tax on the slices, or 'relieved liability'.
The slice is £30,000/6 = £5,000
Income | Calculation | Tax | |
Salary | £12,570 | Personal allowance @ 0% | N/A |
Salary | £32,700 | Basic rate @ 20% | N/A |
Interest | £200 | Personal savings allowance @ 0% | N/A |
Dividends | £500 | Dividend allowance @ 0% | N/A |
Dividends | £2,000 | Dividend higher rate @ 33.75% | N/A |
Bond gain | £300 | Personal savings allowance @ 0% | £0 |
Bond gain | £2,000 | Basic rate @ 20% | £400 |
Bond gain | £2,700 | Higher rate @40% | £1,080 |
Tax treated as paid | £5,000 @ 20% | (£1,000) | |
Tax on slice | £480 | ||
Tax on all slices (2b) | £480 x 6 | £2,880 |
Top slice relief (2a -2b) = £2,600
Step 3 - Deduct the relief from the full tax liability
Income | Calculation | Tax | |
Salary | £12,570 | Personal allowance @ 0% | £0 |
Salary | £32,700 | Basic rate @ 20% | £6,540 |
Interest | £200 | Personal savings allowance @ 0% | £0 |
Bond gain | £300 | Personal savings allowance @ 0% | £0 |
Bond gain | £4,500 | Basic rate @ 20% | £900 |
Bond gain | £25,200 | Higher rate @ 40% | £10,080 |
Dividends | £500 | Dividend allowance @ 0% | £0 |
Dividends | £2,000 | Dividend higher rate @ 33.75% | £675 |
Total tax | £18,195 | ||
Top slicing relief | (£2,600) | ||
Tax due | £15,595 |
The tax on the bond only is £900 + £10,080 - £2,600 = £8,380.
However, there is another tax consequence where the computation includes offshore bond gains and dividends. The £2,000 dividends in excess of the dividend allowance would have fallen into the basic rate band and taxed at 8.75% if there had been no bond gain. But by including the bond gain, they are pushed into the higher rate, resulting in extra tax of £500 (£675-£175).
Example 3 - Bond gain and sliced gain above the higher rate threshold, and reduced personal allowance
Ava has the following income chargeable to tax:
- Salary = £70,270
- Onshore bond gain = £40,000 over 10 years
She will therefore be entitled to the following allowances:
- Personal allowance (PA) of £7,435 (reduced because income exceeds income limit by £10,270)
- A full personal allowance for calculating the relieved liability in Step 2b (because salary plus the sliced gain totals £74,270 i.e. less than £100,000)
- Starting rate band for savings (SRBS) of zero
- Personal savings allowance (PSA) of £500
Step 1 - Total tax liability
Income | Calculation | Tax | |
Salary | £7,435 | Personal allowance @ 0% | £0 |
Salary | £37,700 | Basic rate @ 20% | £7,540 |
Salary | £25,135 | Higher rate @ 40% | £10,054 |
Bond gain | £500 | Personal savings allowance @ 0% | £0 |
Bond gain | £39,500 | Higher rate @ 40% | £15,800 |
Total tax | £33,394 |
Step 2 - Top slicing relief
Step 2a - Total tax on full bond gain
Income | Calculation | Tax | |
Salary | £7,435 | Personal allowance @ 0% | N/A |
Salary | £37,700 | Basic rate @ 20% | N/A |
Salary | £25,135 | Higher rate @ 40% | N/A |
Bond gain | £500 | Personal savings allowance @ 0% | £0 |
Bond gain | £39,500 | Higher rate @ 40% | £15,800 |
Tax treated as paid | £40,000 @ 20% | (£8,000) | |
Total tax (2a) | £7,800 |
Step 2b - Tax on the slices, or 'relieved liability'.
The slice is £40,000/10 = £4,000
Income | Calculation | Tax | |
Salary | £12,570 | Personal allowance @ 0% | N/A |
Salary | £37,700 | Basic rate @ 20% | N/A |
Salary | £20,000 | Higher rate @ 40% | N/A |
Bond gain | £500 | Personal savings allowance @ 0% | £0 |
Bond gain | £3,500 | Higher rate @ 40% | £1,400 |
Tax treated as paid | £4,000 @ 20% | (£800) | |
Tax on slice | £600 | ||
Tax on all slices (2b) | £600 x 10 | £6,000 |
Top slice relief (2a -2b) = £1,800
Step 3 - Deduct the relief from the full tax liability
Income | Calculation | Tax | |
Salary | £7,435 | Personal allowance @ 0% | £0 |
Salary | £37,700 | Basic rate @ 20% | £7,540 |
Salary | £25,135 | Higher rate @ 40% | £10,054 |
Bond gain | £500 | Personal savings allowance @ 0% | £0 |
Bond gain | £39,500 | Higher rate @ 40% | £15,800 |
Total tax | £33,394 | ||
Top slicing relief | (£1,800) | ||
Tax treated as paid* | £40,000 x 20% | (£8,000) | |
Tax due | £23,594 |
The tax on the bond only is £15,800 - £1,800 - £8,000 = £6,000
So, although the whole gain is in the higher rate, the amount of tax is less than might be expected because of the personal savings allowance. Had the PSA not been available to use against the bond, the additional tax would have been £8,000.
* Because the bond is onshore, the tax treated as paid, or notional tax credit, can be deducted from the final liability after the top slice relief.
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