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Tax - Insurance

Globalisation, the continued growth of international trade, the shifting political landscapes and the increasing flow of shared information have made tax matters material a challenging issue for many businesses. 

When the US tax reform, the Brexit, BEPS, European Court of Justice decision, disruptive technological forces and regulatory bodies around the world are reshaping the global tax landscapes for years to come, a tax centric holistic approach able to articulate both global and local considerations is necessary . Thanks to a wide breadth of services coupled with a deep insurance expertise level, the PwC Luxembourg tax team can assistant you.  

Our key insurance tax services include:


Our insurance professionals provide coordinated services for tax planning and help insurers identify and implement tax-planning opportunities. We also provide assistance in business concerning taxing authorities on premium tax issues.

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Our international insurance professionals provide a range of services to both outbound and inbound clients. Our outbound services offers a number of services which include foreign tax credit analysis, tax efficient cross-border financing, and assistance in setting up and running overseas operations. Our inbound services include permanent establishment analysis, financing strategies, and assistance in connection with mergers and acquisitions.

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Information reporting

We help insurers to navigate through reporting and withholding obligations associated with various types of payments including those related to life and non-life insurance products, deferred compensation, and commissions. We can also support the evaluation of the client systems and procedures, as well as advises them regarding the abatement of proposed penalties associated with information returns and failures to properly deposit withheld tax.

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Risk management

We work with clients to evaluate alternatives for their risk management programs and assist them in the implementation of the chosen solution. We evaluate current programs and design alternative structures for deductibles, attachment points and aggregate stop-losses taking into account market risk-transfer price alternatives.

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Tax accounting

The continuous developments in financial and tax reporting require tax practitioners to work closely with financial reporting staff to insure proper reported. For our non-audit clients, our tax provision services assist taxpayers in the preparation of their tax accruals and other related projects, such as an analysis of tax positions at quarter/year-end, and/or deferred tax reviews.

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Mergers and acquisitions

From strategic deal planning and structuring to due diligence and post deal integration, our insurance M&A team provides creative solutions to insurance tax problems inherent in reorganizations, reinsurance transactions, spin-offs, dispositions, public offerings, and capital issues, such as de-mutualisations, and the formation of mutual holding companies. More specifically, we assist insurers with foreign and domestic acquisition planning, restructuring corporate entities, analyses of stock versus asset acquisitions, liquidations, and life/non-life consolidated return issues.

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Transfer pricing

The increasing complexity of businesses and globalization, together with the more onerous transfer pricing documentation requirements around the world and the demands for more tax transparency, mean that the need a ‘fit for purpose’ transfer pricing strategy and execution is vital. We can help you manage your transfer pricing risks and identify opportunities to improve the efficiency of your tax function.

Our insurance transfer pricing specialists are experts in the different aspects of inter-company pricing which include pricing structure planning, documentation compliance, and funding management. We assist clients with local and international tax transfer pricing issues such as profit allocations to branches, headquarter costs allocations and permanent establishments analyses. Our transfer pricing specialists understand the potential impacts of technology (i.e., smart contracts, value chain disruptions) and can help insurers navigate their new landscapes. 

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Captive reinsurance or insurance companies

PwC provides a broad range of services to captive insurance companies. We provide services to a number of pre-eminent industrial and financial services organizations in the US and around the world. Our multi-disciplinary approach includes experienced tax, actuarial, risk management, accounting, regulatory and business recovery professionals who assist insurers quickly identify, plan and address business issues, opportunities and challenges, and reduce the risk of unexpected occurrences.

Our services mirror business cycle needs, including:

  • Establishment - Formation assistance, captive tax planning, structuring and feasibility studies.
  • Enhancement - Risk management, tax and operational reviews of existing and planned programs, including "Captive Health Checks" of existing captives.
  • Ongoing maintenance - Audit and assurance services, actuarial reserve studies and statutory certifications, tax compliance and actuarial support for transfer pricing analyses.
  • Closure - Process improvement reviews, professional advice on run-off or commutation strategies (including managed wind-ups).

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Insurance products

Life insurance and annuity products are continually evolving as demographics and needs change. We help clients answer their tax-related questions about insurance products.

PwC Luxembourg has assembled a dedicated team of VAT, transfer pricing, personal tax, tax reporting, tax compliance and tax consulting specialists who can help you overcome these challenges in an efficient and coordinated manner. Should you have any related questions on the subject, please do not hesitate to contact:

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Contact us

Géraud de Borman

Géraud de Borman

Corporate Tax Partner, PwC Luxembourg

Tel: +352 49 48 48 3161

Frédéric  Wersand

Frédéric Wersand

VAT Partner, PwC Luxembourg

Tel: +352 49 48 48 3111

Christophe Hillion

Christophe Hillion

Partner, Transfer Pricing

Tel: +352 49 48 48 2031

Pierre Kirsch

Pierre Kirsch

Tax Partner, PwC Tax Information reporting Sàrl, PwC Luxembourg

Tel: +352 49 48 48 4031

Julien Treffort

Julien Treffort

Partner, Personal Tax, PwC Luxembourg

Tel: +352 49 48 48 3349

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