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GIM10000 | Non-resident insurers

From HM Revenue & Customs · General Insurance Manual

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.

Contents35 entries

  1. GIM10010Non-resident insurers: accounting requirements: non-UK companies
  2. GIM10020Non-resident insurers: regulatory background: general
  3. GIM10030Non-resident insurers: regulatory background: EEA insurers: ‘EEA firms’ with a branch or providing services in the UK: passport rights
  4. GIM10040Non-resident insurers: regulatory background: EEA insurers: ‘Treaty firms’ with a branch or providing services in the UK: individual Treaty rights
  5. GIM10050Non-resident insurers: regulatory background: EEA insurers: meaning of ‘branch’ and ‘provision of services’
  6. GIM10060Non-resident insurers: regulatory background: EEA insurers: further guidance on meaning of ‘branch’ and ‘provision of services’
  7. GIM10070Non-resident insurers: regulatory background: EEA insurers: FSA requirements on ‘branches’, ‘provision of services’ and ‘Treaty firms’
  8. GIM10080Non-resident insurers: regulatory background: EEA insurers: no assets or regulatory returns required in UK
  9. GIM10090Non-resident insurers: regulatory background: non-EEA insurers: general
  10. GIM10100Non-resident insurers: regulatory background: non-EEA insurers: FSA returns
  11. GIM10110Non-resident insurers: scope of UK taxing rights: background
  12. GIM10115Non-resident insurers: scope of UK taxing rights: double taxation treaties
  13. GIM10120Non-resident insurers: scope of UK taxing rights: section 11 ICTA and OECD Model Treaty: introduction
  14. GIM10121Non-resident insurers: scope of UK taxing rights: section 11 ICTA and OECD Model Treaty: permanent establishment
  15. GIM10122Non-resident insurers: scope of UK taxing rights: the corporation tax charge: accounting periods beginning on or after 1 January 2003: charge on profits
  16. GIM10123Non-resident insurers: scope of UK taxing rights: the corporation tax charge: accounting periods beginning on or after 1 January 2003: 'independent enterprise'
  17. GIM10124Non-resident insurers: scope of UK taxing rights: the corporation tax charge: accounting periods beginning on or after 1 January 2003: 'free assets'
  18. GIM10130Non-resident insurers: scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: application to insurers
  19. GIM10140Non-resident insurers: scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: attribution of the investment return
  20. GIM10150Non-resident insurers: scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: attribution of the investment return: regulatory guidance
  21. GIM10160Non-resident insurers: scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: attribution of the investment return: significance of solvency margin
  22. GIM10170Non-resident insurers: scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: attribution of the investment return: OECD Commentary
  23. GIM10180Non-resident insurers: scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: attribution of the investment return: traditional Methods 1 and 2
  24. GIM10190Non-resident insurers: scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: attribution of the investment return: treatment of interest
  25. GIM10200Non-resident insurers: scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: attribution of the investment return: mutual agreement procedure
  26. GIM10210Non-resident insurers: scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: OECD Report on the Attribution of Profits: background
  27. GIM10220Non-resident insurers: scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: OECD Report on the Attribution of Profits: Step 1
  28. GIM10221Non-resident insurers: 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:
  29. GIM10225Non-resident insurers: 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:
  30. GIM10230Non-resident insurers: 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
  31. GIM10231Non-resident insurers: scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: OECD Report on the Attribution of Profits: internal and external reinsurance
  32. GIM10235Non-resident insurers: 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
  33. GIM10240Non-resident insurers: other taxation issues: taxation of non- residents generally
  34. GIM10250Non-resident insurers: other taxation issues: FOTRA securities and War Loan
  35. GIM10260Non-resident insurers: other taxation issues: loan relationships and derivative contracts