GIM10000 - Non-resident insurers
A non-resident general insurance company, like any non-resident company, is chargeable to corporation tax on its trading activities carried on in the United Kingdom through a permanent establishment - ICTA88/S11 (1).
This Chapter explains the accounting, regulatory and taxation aspects of the treatment of non-resident insurers which differ from those of resident insurers.
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Accounting requirements: non-UK companies |
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Regulatory background: general |
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Regulatory background: EEA insurers: ‘EEA firms’ with a branch or providing services in the UK: passport rights |
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Regulatory background: EEA insurers: ‘Treaty firms’ with a branch or providing services in the UK: individual Treaty rights |
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Regulatory background: EEA insurers: meaning of ‘branch’ and ‘provision of services’ |
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Regulatory background: EEA insurers: further guidance on meaning of ‘branch’ and ‘provision of services’ |
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Regulatory background: EEA insurers: FSA requirements on ‘branches’, ‘provision of services’ and ‘Treaty firms’ |
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Regulatory background: EEA insurers: no assets or regulatory returns required in UK |
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Regulatory background: non-EEA insurers: general |
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Regulatory background: non-EEA insurers: FSA returns |
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Scope of UK taxing rights: background |
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Scope of UK taxing rights: double taxation treaties |
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Scope of UK taxing rights: section 11 ICTA and OECD Model Treaty: introduction |
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Scope of UK taxing rights: section 11 ICTA and OECD Model Treaty: permanent establishment |
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Scope of UK taxing rights: the corporation tax charge: accounting periods beginning on or after 1 January 2003: charge on profits |
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Scope of UK taxing rights: the corporation tax charge: accounting periods beginning on or after 1 January 2003: ‘independent enterprise’ |
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Scope of UK taxing rights: the corporation tax charge: accounting periods beginning on or after 1 January 2003: ‘free assets’ |
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Scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: application to insurers |
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Scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: attribution of the investment return |
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Scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: attribution of the investment return: regulatory guidance |
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Scope of UK taxing rights: : attribution of the investment return: significance of solvency margin |
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Scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: attribution of the investment return: OECD Commentary |
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Scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: attribution of the investment return: traditional Methods 1 and 2 |
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Scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: attribution of the investment return: treatment of interest |
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Scope of UK taxing rights: : section 11 ICTA & Article 7 OECD Model: attribution of the investment return: mutual agreement procedure |
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Scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: OECD Report on the Attribution of Profits: background |
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Scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: OECD Report on the Attribution of Profits: Step 1 - determining the activities and conditions of the hypothetical distinct and separate enterprise: the key entrepreneurial risk taking function |
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Scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: OECD Report on the Attribution of Profits: Step 1 - determining the activities and conditions of the hypothetical distinct and separate enterprise: attribution of assets |
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Scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: OECD Report on the Attribution of Profits: Step 1 - determining the activities and conditions of the hypothetical distinct and separate enterprise: investment yield |
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Scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: OECD Report on the Attribution of Profits: Step 2: determining the profits of the hypothetical distinct and separate enterprise |
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Scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: OECD Report on the Attribution of Profits: internal and external reinsurance |
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Scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: OECD Report on the Attribution of Profits: Model Article 7(4) - apportionment methods: Model Article 7(7) - interaction with other Articles |
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Other taxation issues: taxation of non-residents generally |
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Other taxation issues: FOTRA securities and War Loan |
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Other taxation issues: loan relationships and derivative contracts |
