GIM11000 - Captive insurers


This section provides guidance on the tax treatment of captive insurers. It summarises the material in the International Tax Handbook and (ITH) and International Manual (INTM) and provides additional guidance on CFCs, CTSA and funded accounting, and certain types of business carried on by captives, such as mortgage indemnity and warranty business.

GIM11010Background
GIM11020Tax havens and local organisation
GIM11030Fronting
GIM11040Commercial reasons for establishing a captive
GIM11050Taxation issues
GIM11060Taxation issues: possible approaches
GIM11070Controlled foreign companies: general rules
GIM11080Controlled foreign companies: funded accounting
GIM11090Controlled foreign companies: funded accounting: special tax rules
GIM11100Controlled foreign companies: funded accounting: special tax rules: returns and dividends
GIM11110Controlled foreign companies: funded accounting: special tax rules: time limits for enquiries, returns and payment of dividends where an ADP is followed
GIM11120Controlled foreign companies: 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
GIM11130Controlled foreign companies: funded accounting: tax rules: time limits for enquiries, returns and payment of dividends where the CFC fails to pay the dividend within the time limit
GIM11140Controlled foreign companies: funded accounting: risk assessment
GIM11150Controlled foreign companies: funded accounting: mixed business
GIM11160Equalisation reserves
GIM11170Section 107 FA 2000
GIM11180Mortgage indemnity business
GIM11190Warranties, creditor business and service agreements: FA 2003