24 February 2016 OECD BEPS and EU Anti-Tax Avoidance Directive have implications for captive insurers Over the last five years, global tax authorities have increasingly scrutinized captive insurance arrangements, focusing on questions relating to substance, commercial purpose and pricing. In what is likely to further reinforce this trend, the main work streams of the two year Organization for Economic Co-operation and Development (OECD) Base Erosion and Profit Shifting (BEPS) project concluded in October 2015 with a series of measures that bring fundamental changes to the international tax landscape and could significantly affect captive insurers. While some of the OECD changes have yet to be fully concluded or implemented in European Union (EU) Member States, others may have immediate effect in some jurisdictions through existing domestic legislation. The OECD will be undertaking further work during 2016 and 2017 to establish specific guidance on the transfer pricing of financial transactions, which includes captive insurance arrangements. Document ID: 2016-0370 |
