Chapter INTM286420

Published date09 April 2016
Record NumberINTM286420
This applies for relevant accounting periods beginning on or after 1 January 2013. Chapter 7.

TIOPA10/Part 9A/CH7 looks at profits that arise from captive insurance business. Profits that are potentially subject to a Chapter 7 charge are those that arise from the insurance (and reinsurance) of risks originating within a UK connected group company and the insurance of risks with UK resident persons who have bought goods or services from a UK connected company. A “UK connected company” means a UK resident company connected with Company X (INTM286320) or a non-UK resident company connected with Company X acting through a UK PE.

The basic rule is adapted for captive insurance business carried on through a PE in an EEA territory, so that it only applies to the extent there is no significant UK non-tax reason for entering into the contract of insurance arrangement.

A contract of reinsurance is excluded from the Chapter 7 rules where the insured party is neither a UK resident company...

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