Tax aspects of insurance entities

A good understanding of the tax rules is key for any business and is particularly important in the insurance industry. Ensuring having the right knowledge both (i) in direct taxes (including transfer pricing) and (ii) in VAT can help to anticipate and manage tax risks upfront and may open the door to a reduction of processing costs and other charges linked to administrative demands.

There is an increasing complexity of national, European regulations and international legislations such as the OECD BEPS plan addressing Base Erosion and Profit Shifting (BEPS), along with a growing volume of court decisions on the subject. VAT rules are not easier to deal with: scope of exemptions, mitigation strategies, reporting requirements are high on the agenda of tax directors and CFOs. PwC Academy is happy to offer you an innovative training session which gets you up to speed on the main tax considerations and issues for the insurance industry in Luxembourg.

This training includes future expected changes in the legislation as applicable as well as the regulatory changes that could trigger unexpected tax consequences when business models and fee structures are revisited.

By the end of this training, the participants will be able:

• to have a good understanding of the current Luxembourg taxation of the insurance industry including the aspects linked to the insurance entity itself, the distribution and investment activity in order to handle tax matters linked to the insurance industry methodically;
• identify the upcoming tax challenges the insurance industry would face;
• develop a critical mindset with respect to tax aspects linked to the insurance industry.

The course will focus on the following:

• Taxation of the insurance entity itself (i.e. corporate tax, VAT and TP aspects)
• Taxation of the distribution activity (e.g. development of the digital distribution on related tax impact)
• Taxation of the investments activity
• Impact of the EU Pillar 2 on insurance entities
• Expectations regarding tax regulations/legislations that may impact the insurance industry

This training is coordinated by David Schaefer and Géraud de Borman, Partners in the PwC Tax department.

David Schaefer is a partner with over 15 years of experience in PwC Luxembourg’s VAT department, including a six-month secondment in PwC London advising international groups. He specialises in advising clients on complex indirect taxation issues, particularly input VAT recovery optimisation, and provides guidance on VAT matters related to real estate held through Luxembourg structures, mergers, acquisitions, and group restructuring. David regularly delivers VAT training and contributes to key VAT publications. He serves major international real estate and Pan European infrastructure clients, coordinating assignments across VAT and other service teams to ensure compliance with indirect tax obligations.

Géraud de Borman is a partner in the Tax department with over 25 years of experience advising financial industry and multinational companies on corporate taxation, mergers, IPOs, and special operations. He specialises in insurance, reinsurance, banking, and financial sectors, focusing on captive solutions, restructuring, and tax impacts related to the transition to Solvency II. As the Luxembourg leader in the insurance tax network, he provides tax analysis on Solvency II’s effects on existing structures. His notable projects include optimizing insurance/reinsurance company locations, assisting international groups in business model transitions, and supporting major players in migrating operations to Luxembourg, including Brexit-related work.