After section 465 insert—

“465AAmounts for which individuals liable to be treated as highest part of total income

(1)

This section applies if—

(a)

an individual is liable for tax under this Chapter in respect of an amount, and

(b)

the individual is treated by section 530 as having paid income tax at the savings rate on the amount.

(2)

The amount is treated as the highest part of the individual’s total income.

(3)

Subsection (2) has effect for all income tax purposes except the purposes of sections 535 to 537 (gains from contracts for life insurance etc: top slicing relief).

(4)

See section 1012 of ITA 2007 (relationship between highest part rules) for the relationship between—

(a)

the rule in subsection (2), and

(b)

other rules requiring particular income to be treated as the highest part of a person’s total income.”