GIM10000 - Non-resident insurers

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.

1. GIM10010

   Accounting requirements: non UK companies
2. GIM10020

   Regulatory background: general
3. GIM10030

   Regulatory background: EEA insurers: 'EEA firms' with a branch or providing services in the UK: passport rights
4. GIM10040

   Regulatory background: EEA insurers: ‘Treaty firms’ with a branch or providing services in the UK: individual Treaty rights
5. GIM10050

   Regulatory background: EEA insurers: meaning of 'branch' and 'provision of services'
6. GIM10060

   Regulatory background: EEA insurers: further guidance on meaning of 'branch' and 'provision of services'
7. GIM10070

   Regulatory background: EEA insurers: FSA requirements on 'branches', 'provision of services' and 'Treaty firms'
8. GIM10080

   Regulatory background: EEA insurers: no assets or regulatory returns required in UK
9. GIM10090

   Regulatory background: non-EEA insurers: general
10. GIM10100

    Regulatory background: non-EEA insurers: FSA returns
11. GIM10110

    Scope of UK taxing rights: background
12. GIM10115

    Scope of UK taxing rights: double taxation treaties
13. GIM10120

    Scope of UK taxing rights: section 11 ICTA and OECD Model Treaty: introduction
14. GIM10121

    Scope of UK taxing rights: section 11 ICTA and OECD Model Treaty: permanent establishment
15. GIM10122

    Scope of UK taxing rights: the corporation tax charge: accounting periods beginning on or after 1 January 2003: charge on profits
16. GIM10123

    Scope of UK taxing rights: the corporation tax charge: accounting periods beginning on or after 1 January 2003: ‘independent enterprise’
17. GIM10124

    Scope of UK taxing rights: the corporation tax charge: accounting periods beginning on or after 1 January 2003: ‘free assets’
18. GIM10130

    Scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: application to insurers
19. GIM10140

    Scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: attribution of the investment return
20. GIM10150

    Scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: attribution of the investment return: regulatory guidance
21. GIM10160

    Scope of UK taxing rights: : attribution of the investment return: significance of solvency margin
22. GIM10170

    Scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: attribution of the investment return: OECD Commentary
23. GIM10180

    Scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: attribution of the investment return: traditional Methods 1 and 2
24. GIM10190

    Scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: attribution of the investment return: treatment of interest
25. GIM10200

    Scope of UK taxing rights: : section 11 ICTA & Article 7 OECD Model: attribution of the investment return: mutual agreement procedure
26. GIM10210

    Scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: OECD Report on the Attribution of Profits: background
27. GIM10220

    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:
28. 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: attribution of assets
29. 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: investment yield
30. 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
31. GIM10231

    Scope of UK taxing rights: section 11 ICTA & Article 7 OECD Model: OECD Report on the Attribution of Profits: internal and external reinsurance
32. 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
33. GIM10240

    Other taxation issues: taxation of non-residents generally
34. GIM10250

    Other taxation issues: FOTRA securities and War Loan
35. GIM10260

    Other taxation issues: loan relationships and derivative contracts