As the title may suggest, client is not UK resident (and hasn't been for some time) and has a chargeable event gain
IPTM3731 mentions that time apportionment is available for UK policies issued after 6.4.13 where there are periods of non-residence. Policy is older than that, so I revert to my assumption that UK source = UK tax unless treaty says otherwise
However, IPTM3734 then cheerfully informs us that it isn’t taxable at all in the UK if the individual is nonresident unless the non-residence is temporary (which it isn't)
What? Unusually despite the top slicing this does matter, as client has a capital gain on a UK property and so the rate of capital gains is affected by whether or not said chargeable event is subject to UK tax.
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