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HMRC internal manual

General Insurance Manual

Reinsurance and other forms of risk transfer: financial reinsurance and alternative risk transfer (ART): insurance linked securities: income tax

Regulation 5 of the Risk Transformation (Tax) Regulations 2017 ensures that the duty to deduct income tax under section 874 ITA 2007 does not apply to payments of interest made to investors holding securities issued by a QTV (or cell of a QTV).