In the calculation of top-slicing relief on a chargeable event gain, beneficial ordering applied and other reliefs were to be taken into account, and the appellant’s top-slicing relief calculation had not been calculated incorrectly.

The deceased (RY) died on 3 March 2018. Between 6 April 2017 and his death, RY was in receipt of pension income (including his state pension) of £49,460, savings income of £185 and dividend income of £52. In the same year, a single chargeable event gain of £232,275 arose in connection with three life insurance policies, of which two were held for 23 years and one was held for 22 years.<