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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 general insurers: equalisation reserves

GIM11160 | Captive general insurers: equalisation reserves

From HM Revenue & Customs · General Insurance Manual

SI1999/1408 Regulation 7 ensures that the Equalisation Reserves Rules (see GIM7290) are deductible in computing distributable profits for captive insurers, provided the reserves are maintained in the same way as is required for UK companies or branches. But a CFC cannot obtain a deduction for an equalisation reserve where it leaves the fund open beyond the end of the third year following the replacement of the technical provision. Captive insurers using funded accounting are thus in the same position as UK companies or branches. INTM213080 gives more details.

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