GIM7000 - Equalisation reserves
This section sets out the tax treatment of ‘equalisation reservesâ€�, which general insurers were required to maintain for certain lines of general (non-life) insurance business for accounting periods ending on or after 23 December 1996 and ending before 1 January 2016. »Ê¹ÚÌåÓýapp Prudential Regulation Authority (PRA) regulatory rules on these reserves referred to ‘equalisation provisionsâ€� because they were treated by the PRA as liabilities rather than as reserves, but the tax legislation still referred to ‘equalisation reservesâ€�. This section of the General Insurance Manual refers to ‘reservesâ€� rather than ‘provisionsâ€�.
»Ê¹ÚÌåÓýapp relevant legislation was contained at ICTA88/S444BA to ICTA88/S444BD and the Insurance Companies (Reserves) (Tax) Regulations 1996, SI1996/2991.
This legislation was repealed by FA12/S26. »Ê¹ÚÌåÓýapp repeal was effective for accounting periods ending on or after 1 January 2016, the date that the Solvency II Directive (2009/138/EC) came into force.
»Ê¹ÚÌåÓýapp repeal of the legislation for the tax treatment of equalisation reserves affects general insurance companies who maintain such reserves and corporate and partnership members of Lloyd’s who maintain equivalent reserves in accordance with the Lloyd’s regulations (see LLM3400 et seq.).
Guidance on the FA 2012 changes can be found at onwards.
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GIM7010Background
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GIM7020Application of the regulatory rules
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GIM7030Classes of business affected
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GIM7040Classes other than credit business: limits on transfers in and out
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GIM7050Classes other than credit business: de minimus limit
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GIM7060Classes other than credit business: calculation
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GIM7070Classes other than credit business: creation of the reserve
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GIM7080Classes other than credit business: ring-fencing
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GIM7090Classes other than credit business: ring-fencing: maximum level of reserve
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GIM7100Classes other than credit business: summary of requirements
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GIM7110Classes other than credit business: example
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GIM7120Credit business: limits and calculation
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GIM7130Credit business: de minimis limits
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GIM7140Annual accounting on an underwriting year basis
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GIM7150Cessations and transfers of business
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GIM7160Cessations and transfers of business: transfers of a block or all of the business
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GIM7170Regulatory return forms
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GIM7180»Ê¹ÚÌåÓýapp tax rules
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GIM7190»Ê¹ÚÌåÓýapp tax rules: tax adjustments to premiums or claims
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GIM7200»Ê¹ÚÌåÓýapp tax rules: errors in returns or accounts
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GIM7210»Ê¹ÚÌåÓýapp tax rules: differences between accounting periods and financial years
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GIM7220»Ê¹ÚÌåÓýapp tax rules: funded accounting
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GIM7230»Ê¹ÚÌåÓýapp tax rules: shadow equalisation reserves
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GIM7240»Ê¹ÚÌåÓýapp tax rules: shadow equalisation reserves: worked example
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GIM7250»Ê¹ÚÌåÓýapp tax rules: election not to take a tax deduction
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GIM7260»Ê¹ÚÌåÓýapp tax rules: parts of reserves built up prior to the tax rules
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GIM7270»Ê¹ÚÌåÓýapp tax rules: cessations
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GIM7280»Ê¹ÚÌåÓýapp tax rules: insurers not regulated in the UK: non-statutory reserves
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GIM7290»Ê¹ÚÌåÓýapp tax rules: insurers not regulated in the UK: non-statutory reserves: tax relief for UK branches of EEA insurers
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GIM7300»Ê¹ÚÌåÓýapp tax rules: insurers not regulated in the UK: non-statutory reserves: tax relief for UK companies trading outside EEA
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GIM7310»Ê¹ÚÌåÓýapp tax rules: insurers not regulated in the UK: controlled foreign companies
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GIM7320»Ê¹ÚÌåÓýapp tax rules: insurers not regulated in the UK: UK branches of non-EEA insurers
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GIM7330»Ê¹ÚÌåÓýapp tax rules: tax credit relief
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GIM7340»Ê¹ÚÌåÓýapp tax rules: example of apportionment for double taxation relief
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GIM7350»Ê¹ÚÌåÓýapp tax rules: anti-avoidance
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GIM7360»Ê¹ÚÌåÓýapp tax rules: mutuals and partial mutuals
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GIM7370»Ê¹ÚÌåÓýapp tax rules: group regulatory returns
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GIM7380Recalculation of reserves for tax purposes
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GIM7390International Accounting Standards (IAS)
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GIM7400Repeal of equalisation reserves tax legislation for accounting periods ending on or after 1 January 2016
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GIM7410Repeal of equalisation reserves tax legislation for accounting periods ending on or after1 January 2016: Introduction
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GIM7420Repeal of equalisation reserves tax legislation for accounting periods ending on or after1 January 2016: Insurer ceasing to trade during transitional period
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GIM7430Repeal of equalisation reserves tax legislation for accounting periods ending on or after1 January 2016: Companies that had previously elected not to take a tax deduction
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GIM7440Repeal of equalisation reserves tax legislation for accounting periods ending on or after1 January 2016: Election to accelerate receipts
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GIM7450Repeal of equalisation reserves tax legislation for accounting periods ending on or after1 January 2016: Transfer of whole or part of the business during the transitional period
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GIM7460Repeal of equalisation reserves tax legislation for accounting periods ending on or after1 January 2016: Transfer of the whole business or substantially the whole business: example
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GIM7470Repeal of equalisation reserves tax legislation for accounting periods ending on or after1 January 2016: Transfer of part of the business
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GIM7480Repeal of equalisation reserves tax legislation for accounting periods ending on or after1 January 2016: Interaction with Double Taxation Relief
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GIM7490Repeal of equalisation reserves tax legislation for accounting periods ending on or after1 January 2016: Interaction with Double Taxation Relief: Examples
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GIM7490Repeal of equalisation reserves tax legislation for accounting periods ending on or after1 January 2016: Interaction with Double Taxation Relief: Examples