The Overseas Insurers (Tax Representatives) Regulations 1999

9.  The circumstances described in this paragraph are where the aggregate amount of connected gains in the year of assessment or financial year exceeds one half of the basic rate limit for that year of assessment or for the year of assessment corresponding to that financial year and, for the purposes of this paragraph, a gain is connected with another gain where–

(a) both gains arise in connection with policies or contracts containing obligations which, immediately before the relevant event in question, were obligations of the same overseas insurer;

(b) the policy holder of those policies and contracts is the same; and

(c) both gains arise in the same year of assessment or, where the policy holder is a company, the same financial year.