LAM12300 - International and cross border: Diverted Profits Tax

There are no special diverted profits tax provisions for life insurance companies.

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

• Insurance groups with intragroup reinsurance DPT1390 example 1.
• Insurance groups providing offshore bonds DPT1390 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.