610U.K.After section 644 insert—
(1)No liability to income tax arises in respect of a pension or annuity payment if or to the extent that—
(a)were the payment an annual payment falling within Chapter 7 of Part 5 of ITTOIA 2005, it would be exempt from income tax under section 735 of that Act (health and employment insurance payments), and
(b)it meets conditions A and B.
(2)Condition A is that the payments are made—
(a)to a person (“the pensioner”) who made payments or contributions in respect of premiums under an insurance policy which another person took out wholly or partly for the pensioner's benefit, or
(b)to the pensioner's husband or wife.
(3)Condition B is that the payments are attributable on a just and reasonable basis to the payments or contributions in respect of premiums.”