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.
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.
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.
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 affect on the insurance industry