Chapter GIM8360

Published date15 April 2016
Record NumberGIM8360
CourtHM Revenue & Customs

The introduction of FRS5 (GIM8270) and the ABI SORP (Statement of Recommended Practice) improved the clarity of accounting guidance. Most financial insurance and reinsurance will be accounted for in a way that is acceptable for tax purposes. On the other hand, the market for financial insurance and reinsurance is a growing one. The tax haven-based sellers of financial insurance continue to invent new products, disclosure of which may not always be obliged by FRS5 and the SORP. Financial reinsurance arrangements continue to present a risk.

Where financial reinsurance does exist, the premiums payable are likely to be substantial, and the profile of the transaction will therefore be high and easier to detect. For any company regulated by the Financial Services Authority, an insurer’s material exposure to major treaty and facultative reinsurers must be disclosed, and reinsurers must disclose major cedants. The requirements are in Rules 9.25 (treaty reinsurers), 9.26 (facultative reinsurers) and 9.27 (cedants) of IPRU (INS) (Interim Prudential sourcebook for Insurers) Volume 1. IPRU(INS) Volume 2 (Appendix 9.5) provides further information. Rule 9.29 of Volume 1 also requires extensive additional information on the insurer’s use of derivative contracts. These...

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