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.
TPG2022 Chapter X paragraph 10.210
Category: E. Captive insurance, TPG2022 Chapter X: Transfer pricing aspects of financial transactions | Tag: Accurate delineation, Captive insurance, Control functions, Economically significant risk, Financial transactions
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