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+.
Background |
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Tax havens and local organisation |
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Fronting |
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Commercial reasons for establishing a captive |
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Taxation issues: general |
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Taxation issues: possible approaches |
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Controlled foreign companies (CFCs): general rules |
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Controlled foreign companies (CFCs): funded accounting |
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Controlled foreign companies (CFCs): funded accounting: special tax rules |
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Controlled foreign companies (CFCs): funded accounting: special tax rules: returns and dividends |
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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 |
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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 |
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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 |
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Controlled foreign companies (CFCs): funded accounting: risk assessment |
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Controlled foreign companies (CFCs): funded accounting: mixed business |
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Equalisation reserves |
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Section 107 FA2000 |
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Mortgage indemnity business |
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Warranties, creditor business and service agreements: FA 2003 |
