In the process of accurately delineating the actual transaction involving a captive insurance, the economically relevant risks associated with issuing insurance policies, i.e. underwriting, must be identified with specificity. Part IV of the Report on the Attribution of Profits to Permanent Establishments7 provides a description of those risks that include, inter alia, insurance risk, commercial risk or investment risk. These descriptions remain valid for the purpose of this guidance.
TPG2020 Chapter X paragraph 10.209
Posted on | By OECD
Category: OECD Transfer Pricing Guidelines (2017) | Tag: Captive insurance, Economically significant risks, Financial transactions
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- TPG2022 Chapter X paragraph 10.209In the process of accurately delineating the actual transaction involving a captive insurance, the economically relevant risks associated with issuing insurance policies, i.e. underwriting, must be identified with specificity. Part IV of the Report on the Attribution of Profits to Permanent Establishments provides a description of those risks that include,...
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