GIM11000 - Captive insurers


This section provides guidance on the tax treatment of captive insurers. It explains how captive insurers relate to the Controlled Foreign Company (CFC) and CTSA legislation and examines funded accounting, which following its withdrawal in 2005 from UK companies may still be encountered among captives. It also looks at certain types of business particularly associated with captives, such as mortgage indemnity and warranty business. See also the International Manual, notably INTM213030+.


GIM11010

Background

GIM11020

Tax havens and local organisation

GIM11030

Fronting

GIM11040

Commercial reasons for establishing a captive

GIM11050

Taxation issues: general

GIM11060

Taxation issues: possible approaches

GIM11070

Controlled foreign companies (CFCs): general rules

GIM11080

Controlled foreign companies (CFCs): funded accounting

GIM11090

Controlled foreign companies (CFCs): funded accounting: special tax rules

GIM11100

Controlled foreign companies (CFCs): funded accounting: special tax rules: returns and dividends

GIM11110

Controlled foreign companies (CFCs): funded accounting: special tax rules: time limits for enquiries, returns and payment of dividends where an acceptable distribution policy (ADP) is followed: accounting periods beginning before 1 July 2009

GIM11120

Controlled foreign companies (CFCs): funded accounting: tax rules: time limits for enquiries, returns and payment of dividends where it is not established whether the non-resident company is a CFC

GIM11130

Controlled foreign companies (CFCs): funded accounting: tax rules: time limits for enquiries, returns and payment of dividends where the CFC fails to pay a dividend under the acceptable distribution policy (ADP) within the time limit: accounting periods beginning before 1 July 2009

GIM11140

Controlled foreign companies (CFCs): funded accounting: risk assessment

GIM11150

Controlled foreign companies (CFCs): funded accounting: mixed business

GIM11160

Equalisation reserves

GIM11170

Section 107 FA2000

GIM11180

Mortgage indemnity business

GIM11190

Warranties, creditor business and service agreements: FA 2003