The Pillar Two GloBE Rules & Insurance Companies

  1. Exclusion of Certain Insurance Company Income
  2. Covered Taxes
  3. Recapture Exception Accruals
  4. Lack of Physical Substance
  5. Insurance Investment Entities
  6. Restricted Tier One Capital 
  7. Excluded Dividends

There is no specific exemption for insurance companies under the Pillar Two GloBE Rules. Whilst this may not reflect the relevant domestic tax treatment (eg Article 5 of the Dutch Corporate Income Tax Act exempts certain healthcare insurance companies from corporate income tax), the GloBE rules do include a number of insurance specific adjustments. 

In this article we look at the nature of these provisions as well as the impact of the GloBE rules (and the amendments made by the OECD Administrative Guidance) on insurance companies generally. 

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