This edition illstrates the importance of close working between business units and the tax department. Early consideration of the tax rules should maximise reliefs, avoid poor structuring and improve effective data collection. Clearly tax departments need to continue to be proactive in understanding business initiatives.
Data and its use is becoming a big topic. We consider various taxation issues relating to ’big data‘ in the context of insurers, including intellectual property, patent box, research and development plus transfer pricing.
Taxation of corporate debt
A consultation about modernising the rules governing the taxation of corporate debt and derivatives started in June last year. Since then, there has been considerable activity across several working groups. The first round of consultation responses was published in December 2013 and we now have some draft legislation. We take stock of the main points affecting insurers.
The VAT treatment of cross-border service
This can be complex, particularly where the services are provided between members of a corporate group. We summarise the issues and consider the recent referral to the Court of Justice of the European Union (CJEU) – Skandia – which could create significant difficulties and costs. Insurers should consider the impact on any new or existing structures.
Claiming of capital allowances on fixtures in property
Our final article reminds property owners of the rule changes relating to the claiming of capital allowances on property fixtures and the deadline for notifying expenditure. Without the necessary pooling and joint election, no tax relief will ever be available to a purchaser or to subsequent purchasers. This could potentially lead to a reduction in the property’s open market value of the property.
Instant is KPMG’s insurance tax e-newsletter. Instant is regularly released and contains bite-sized summaries of topical tax issues that have an affect on the insurance industry.
This article represents the views of the author only, and does not necessarily represent the views or professional advice of KPMG in the UK.