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Contents

Official guidance
General Insurance Manual

GIM11000 · Captive insurers

  • GIM11010 · Background
  • GIM11020 · Tax havens and local organisation
  • GIM11030 · Fronting
  • GIM11040 · Commercial reasons for establishing a captive
  • GIM11050 · Taxation issues: general
  • GIM11060 · Taxation issues: possible approaches
  • GIM11070 · Controlled foreign companies (CFCs)
  • GIM11080 · Controlled foreign companies (CFCs): funded accounting
  • GIM11090 · Controlled foreign companies (CFCs): funded accounting: special tax rules
  • GIM11100 · Controlled foreign companies (CFCs): funded accounting: special tax rules: returns and dividends
  • GIM11110 · 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
  • GIM11120 · 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
  • GIM11130 · Controlled foreign companies (CFC): 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
  • GIM11140 · Controlled foreign companies (CFCs): funded accounting: risk assessment
  • GIM11150 · Controlled foreign companies (CFCs): funded accounting: mixed business
  • GIM11160 · Captive general insurers: equalisation reserves
  • GIM11170 · Section 107 FA2000
  • GIM11180 · Mortgage indemnity business
  • GIM11190 · Warranties, creditor business and service agreements: FA 2003
  1. Captive insurers
  2. Captive insurers: controlled foreign companies (CFCs): funded accounting: mixed business

GIM11150 | Captive insurers: controlled foreign companies (CFCs): funded accounting: mixed business

From HM Revenue & Customs · General Insurance Manual

A CFC may carry on some business for which it accounts annually and other business for which it accounts on a funded basis. It has 18 months from the date of the replacement of the technical provision in respect of the funded business to make an acceptable distribution, as is the case for a company which accounts wholly on funded basis.

The accounts of a company with mixed business may recognise a loss in its funded business before the closure of the fund. Occasionally the computations might reflect the net position of the annual and funded business. This would be an anticipation of the loss in the funded business. The correct position is that the computation of the profit or loss of the funded business should be undertaken when the fund closes and not before.

The acceptable distribution policy rules were repealed by FA09/SCH16 Part 1 for accounting periods beginning on or after 1 July 2009.

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