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HMRC internal manual

General Insurance Manual

From
HM Revenue & Customs
Updated
, see all updates

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