GIM10000 - Non-resident insurers

A non-resident general insurance company, like any other non-resident company, is chargeable to corporation tax in so far as it is carrying on a trade in the United Kingdom through a branch or agency (ICTA88/S11 (1)).

This section explains the accounting, regulatory and taxation aspects of the treatment of non- resident insurers which differ from those of resident insurers.

GIM10010Accounting requirements: non-UK companies
GIM10020Regulatory background: general
GIM10030Regulatory background: EEA insurers: “EEA firms” with a branch or providing services in the UK: passport rights
GIM10040Regulatory background: EEA insurers: “Treaty firms” with a branch or providing services in the UK
GIM10050Regulatory background: EEA insurers: meaning of “branch” and “provision of services”
GIM10060Regulatory background: EEA insurers: further guidance on meaning of “branch” and “provision of services”
GIM10070Regulatory background: EEA insurers: FSA requirements on “branches”, “provision of services” and “Treaty firms”
GIM10080Regulatory background: EEA insurers: no assets or regulatory returns required in UK
GIM10090Regulatory background: non-EEA insurers: general
GIM10100Regulatory background: non-EEA insurers: FSA returns
GIM10110The scope of UK taxing rights: the corporation tax charge
GIM10120The scope of UK taxing rights: accounting periods beginning before 1 January 2003: section 11 ICTA & Article 7 OECD Model: the arm’s length principle
GIM10130The scope of UK taxing rights: accounting periods beginning before 1 January 2003: section 11 ICTA & Article 7 OECD Model: application to insurers
GIM10140The scope of UK taxing rights: accounting periods beginning before 1 January 2003: section 11 ICTA & Article 7 OECD Model: attribution of the investment return
GIM10150The scope of UK taxing rights: accounting periods beginning before 1 January 2003: section 11 ICTA & Article 7 OECD Model: attribution of the investment return: FSA guidance
GIM10160The scope of UK taxing rights: accounting periods beginning before 1 January 2003: section 11 ICTA & Article 7 OECD Model: attribution of the investment return: solvency margin
GIM10170The scope of UK taxing rights: accounting periods beginning before 1 January 2003: section 11 ICTA & Article 7 OECD Model: attribution of the investment return: OECD Commentary
GIM10180The scope of UK taxing rights: accounting periods beginning before 1 January 2003: section 11 ICTA & Article 7 OECD Model: attribution of the investment return: Method 1 and Method 2
GIM10190The scope of UK taxing rights: accounting periods beginning before 1 January 2003: section 11 ICTA & Article 7 OECD Model: attribution of the investment return: treatment of interest
GIM10200The scope of UK taxing rights: accounting periods beginning before 1 January 2003: section 11 ICTA & Article 7 OECD Model: attribution of the investment return: mutual agreement procedure
GIM10210The scope of UK taxing rights: accounting periods beginning on or after 1 January 2003: section 11 ICTA & Article 7 OECD Model: changes in FA 2003
GIM10220The scope of UK taxing rights: accounting periods beginning on or after 1 January 2003: section 11 ICTA & Article 7 OECD Model: changes in FA 2003: “independent enterprise”
GIM10230The scope of UK taxing rights: accounting periods beginning on or after 1 January 2003: section 11 ICTA & Article 7 OECD Model: changes in FA 2003: “free assets”
GIM10240Other taxation issues: taxation of non-residents generally
GIM10250Other taxation issues: FOTRA securities and War Loan
GIM10260Other taxation issues: loan relationships & derivative contracts