Taxation issues relating to captive insurance companies

Resource Information

The work Taxation issues relating to captive insurance companies represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Books.

Label

Taxation issues relating to captive insurance companies

Creator

• Skaar, A.A

Subject

• captive insurance company
• transfer pricing

Summary

Analysis of the tax treatment of premiums paid to captives. Case law from the US, Germany, the Netherlands, Norway and Australia are compared in order to establish the conditions under which a captive is considered to be a bona fide insurance company. The application of the generally accepted transfer pricing methods is discussed, such as the comparable uncontrolled price method, the cost-plus method and the transactional net margin method, in calculating the arm's length premium rate. Administrative practice in Norway dealing with captives in the oil industry is the point of departure for this discussion

Geographic coverage

International

Language note

English