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Official guidance
General Insurance Manual

GIM10000 · Non-resident insurers

  • GIM10010 · Accounting requirements: non-UK companies
  • GIM10020 · Regulatory background: general
  • GIM10030 · Regulatory background: EEA insurers: ‘EEA firms’ with a branch or providing services in the UK: passport rights
  • GIM10040 · Regulatory background: EEA insurers: ‘Treaty firms’ with a branch or providing services in the UK: individual Treaty rights
  • GIM10050 · Regulatory background: EEA insurers: meaning of ‘branch’ and ‘provision of services’
  • GIM10060 · Regulatory background: EEA insurers: further guidance on meaning of ‘branch’ and ‘provision of services’
  • GIM10070 · Regulatory background: EEA insurers: FSA requirements on ‘branches’, ‘provision of services’ and ‘Treaty firms’
  • GIM10080 · Regulatory background: EEA insurers: no assets or regulatory returns required in UK
  • GIM10090 · Regulatory background: non-EEA insurers: general
  • GIM10100 · Regulatory background: non-EEA insurers: FSA returns
  • GIM10110 · Scope of UK taxing rights: background
  • GIM10115 · Scope of UK taxing rights: double taxation treaties
  • GIM10120 · Scope of UK taxing rights: section 11 ICTA and OECD Model Treaty: introduction
  • GIM10121 · Scope of UK taxing rights: section 11 ICTA and OECD Model Treaty: permanent establishment
  • GIM10122 · Scope of UK taxing rights: the corporation tax charge: accounting periods beginning on or after 1 January 2003: charge on profits
  • GIM10123 · Scope of UK taxing rights: the corporation tax charge: accounting periods beginning on or after 1 January 2003: 'independent enterprise'
  • GIM10124 · Scope of UK taxing rights: the corporation tax charge: accounting periods beginning on or after 1 January 2003: 'free assets'
  • GIM10130 · Scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: application to insurers
  • GIM10140 · Scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: attribution of the investment return
  • GIM10150 · Scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: attribution of the investment return: regulatory guidance
  • GIM10160 · Scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: attribution of the investment return: significance of solvency margin
  • GIM10170 · Scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: attribution of the investment return: OECD Commentary
  • GIM10180 · Scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: attribution of the investment return: traditional Methods 1 and 2
  • GIM10190 · Scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: attribution of the investment return: treatment of interest
  • GIM10200 · Scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: attribution of the investment return: mutual agreement procedure
  • GIM10210 · Scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: OECD Report on the Attribution of Profits: background
  • GIM10220 · Scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: OECD Report on the Attribution of Profits: Step 1
  • GIM10221 · 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:
  • GIM10225 · 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:
  • GIM10230 · 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
  • GIM10231 · Scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: OECD Report on the Attribution of Profits: internal and external reinsurance
  • GIM10235 · 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
  • GIM10240 · Other taxation issues: taxation of non- residents generally
  • GIM10250 · Other taxation issues: FOTRA securities and War Loan
  • GIM10260 · Other taxation issues: loan relationships and derivative contracts
  1. Non-resident insurers
  2. Non-resident insurers: other taxation issues: loan relationships and derivative contracts

GIM10260 | Non-resident insurers: other taxation issues: loan relationships and derivative contracts

From HM Revenue & Customs · General Insurance Manual

GIM5090+ describes the effect of Chapter 2 Part 4 FA 1996 on general insurers. GIM5100 says that companies must use the accounting method shown in the Companies Act accounts, and not the regulatory return. For non-resident companies this includes companies that produce accounts in accordance with regulations made under section 1050(3) of the Companies Act 2006 (those companies where the Home State does not require audit and disclosure of accounts itself). Companies who file their Home State accounts must use those Home State accounts as the basis for the Chapter 2 Part 4 FA 1996 amounts.

For periods beginning on or after 1 October 2002, companies whose Home State accounting practice does not permit the use of mark-to-market where UK GAAP would permit such a method may elect that mark-to-market shall be used for the loan relationships and derivative contracts concerned. See CFM5142+ (loan relationships) and CFM13536+ (derivative contracts).

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