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Recent international tax developments for re/insurance & ILS: Scott Slater, PwC Bermuda


Establishing insurance-linked securities (ILS) investment management operations and the impact of recent international tax developments in the industry was the focus of our latest Artemis Live video interview.

scott-slater-pwc-bermuda-may2023Our latest Artemis Live video interview is with Scott Slater of PwC, a Partner and the Tax Services Leader at PwC Bermuda.

Scott also leads PwC in the Caribbean’s International Tax Services group, which is based in Bermuda and the Cayman Islands.

In this interview we discussed some recent international tax developments and how they could affect insurance, reinsurance and also insurance-linked securities (ILS) interests.

Slater explained that a key area of focus for his practice and team, in relation to insurance-linked securities (ILS) market participants, is the controlled foreign corporation (CFC) rules and the passive foreign investment company (PFIC) rules.

“In the ILS space, most of these structures are either CFC’s or PFIC, and our practice specialises in giving the information that those US investors need to complete their tax returns and satisfy their reporting requirements for making that foreign investment,” he said.

Slater also explained that a component of the work his team at PwC undertakes is to help ILS investment managers identify the right structures for their businesses, from a taxation point of view.

“It’s an interesting conversation, particularly with those asset manager backed ILS vehicles, to explain to them what has to happen in Bermuda and the people they need to get in Bermuda to satisfy those requirements, to mitigate the risk that they’ve somehow created a taxable presence in the US.

“So we work with a lot of clients around the structure, but also the people functions and the activities that need to happen from Bermuda, to achieve that tax result,” he commented.

The full video interview with PwC Bermuda’s Scott Slater is embedded below and can also be viewed, along with previous Artemis Live video interviews, on our dedicated video page.

You can also listen in audio to all of our interviews by subscribing to the Artemis Live podcast here.

All of our Artemis Live video interviews have a focus on reinsurance, ILS and the efficiency of risk transfer and can be accessed here.

You can also listen in audio to these interviews by subscribing to the Artemis Live podcast here.

We’re offering sponsorship opportunities for our broadcasts, including pre-roll adverts or simply sponsor the entire series, as well as facilitating one-off sponsored webinars and virtual events including roundtables, to help companies access our market-leading audience. Please get in touch to discuss.

Register today for ILS Asia 2023, our next insurance-linked securities (ILS) market conference. Held in Singapore, July 13th, 2023.

Artemis ILS Asia 2023 - Insurance-linked securities conference in Singapore

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