Insurance Review - Special Life Edition

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Page 16 of 23

Intra-group reinsurance is a common transaction used by many multinational insurance groups to efficiently allocate capital among their worldwide operations. However, as the parties in an intra-group reinsurance arrangement are related and located in different jurisdictions, these transactions are subject to the transfer pricing rules under section 247 of Canada's Income Tax Act and can be reviewed by the Canada Revenue Agency (CRA) as part of an international tax audit. Intra-group reinsurance Considerations to preempt a transfer pricing dispute with the CRA Insurance Review: A Canadian Perspective 15

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