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Chapter INTM210700

Document Cited in Related
Vincent
Published date09 April 2016
Record NumberINTM210700
CourtHM Revenue & Customs
IssuerHM Revenue & Customs

TIOPA10/S371GA(5) limits the scope of TIOPA10/S371GA(2)(a) in its application to reinsurance contracts. They shall be included only to the extent that the “original contract of insurance” would fall within TIOPA10/S371GA(2)(a).

“Original contract of insurance” (defined at TIOPA10/S371GA(9)), for the purposes of a contract of reinsurance, means the contract of insurance which starts the flow of reinsurance, i.e. the original source of the reinsured risk.

TIOPA10/S371GA(5) therefore excludes contracts of reinsurance where the original insured party is neither a connected UK resident company, nor a UK PE of a connected non-UK resident company, of the CFC.

Example

A UK insurance company “A” writes contracts of insurance with UK resident persons. A CFC connected with A derives profits from...

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