LAM12300 | International and cross border: Diverted Profits Tax

Diverted Profits Tax (DPT) applied to accounting periods beginning between 1 April 2015 and 31 December 2025.

There are no special DPT provisions for life insurance companies.

There are a number of insurance examples provided in the Diverted Profits Tax Guidance which could be relevant:

• Insurance groups with intragroup reinsurance INTM489813 example 1.

• Insurance groups providing offshore bonds INTM489813 example 3.

Reference should be made to the DPT guidance on these points.

The life insurance offshore bond example is the only one which is specific to life insurance. The example sets out one scenario where DPT does not apply. However, DPT can potentially apply in these cases and each case must be assessed on its own facts.

Further information on intragroup reinsurance for life companies is included in LAM10000.

The Unassessed Transfer Pricing Profits (UTPP) rules apply to accounting periods beginning on or after 1 January 2026. There are no special UTPP provisions for life insurance companies, but there are insurance examples provided at INTM489440 and INTM489445.