The accurate delineation of the actual transaction in scenarios involving captive insurance requires identifying whether the captive insurance is performing control functions regarding the economically significant risks associated to the underwriting function – in particular the insurance risk – to determine whether those risks should be allocated to the captive.
TPG2020 Chapter X paragraph 10.210
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By OECD
Category: OECD Transfer Pricing Guidelines (2017) | Tag: Captive insurance, Economically significant risks, Financial transactions
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