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.
| GIM11010 | Background |
| GIM11020 | Tax havens and local organisation |
| GIM11030 | Fronting |
| GIM11040 | Commercial reasons for establishing a captive |
| GIM11050 | Taxation issues |
| GIM11060 | Taxation issues: possible approaches |
| GIM11070 | Controlled foreign companies: general rules |
| GIM11080 | Controlled foreign companies: funded accounting |
| GIM11090 | Controlled foreign companies: funded accounting: special tax rules |
| GIM11100 | Controlled foreign companies: funded accounting: special tax rules: returns and dividends |
| GIM11110 | Controlled foreign companies: funded accounting: special tax rules: time limits for enquiries, returns and payment of dividends where an ADP is followed |
| GIM11120 | Controlled 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 |
| GIM11130 | Controlled 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 |
| GIM11140 | Controlled foreign companies: funded accounting: risk assessment |
| GIM11150 | Controlled foreign companies: funded accounting: mixed business |
| GIM11160 | Equalisation reserves |
| GIM11170 | Section 107 FA 2000 |
| GIM11180 | Mortgage indemnity business |
| GIM11190 | Warranties, creditor business and service agreements: FA 2003 |
