In relation to a chargeable event gain on the surrender of an insurance bond the taxpayer was not entitled to a personal allowance due to the gain but was entitled to a personal allowance in the calculation of hypothetical income undertaken for top slicing relief purposes. 
 
The appellant surrendered a life insurance bond in May 2015. She did not believe that there was any liability, so the surrender was not included in her self-assessment return for 2015/16. However, following an enquiry HM Revenue and Customs (HMRC) amended the appellant’s tax return to show a tax liability. The appellant appealed. 
 
The appellant had purchased the life insurance bond in October 1993 and surrendered it in May 2015. The insurance company issued a chargeable gain certificate showing a gain of £110,721. In 2015/16, the appellant’s other income amounted to £31,101. Her tax return showed a liability