Question to the HM Treasury:
To ask the Chancellor of the Exchequer, how much revenue has accrued to the public purse since 2011 from the (a) introduction of anti-avoidance measures which have modified tax rules that apply to overseas life insurance companies and (b) application of the transfer of business rules when non-profit business is transferred to a non-EEA country.
Legislation was introduced following the 2010 Summer Budget to counter an avoidance scheme involving the transfer of insurance business with unrecognised profits. HM Revenue and Customs (HMRC) is not aware of any instances of this avoidance entered into after the legislation was announced, but it is not possible to say how much tax would otherwise have been lost.
The changes referred to in the question relating to overseas life insurance companies and to transfers of business to non-EEA countries, also proposed in the 2010 Summer Budget, were not anti-avoidance measures. Subsequently Ministers decided not proceed with these measures so HMRC and industry could focus on the substantial changes to the tax rules for life insurance companies introduced in Finance Act 2012.