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Captive industry steps up efforts to attract Canadian companies

Peter Willitts

The Bermuda captive insurance industry is already starting to see the benefits of its marketing push into Canada.Some captives owned by Canadian corporations have already redomiciled to Bermuda from elsewhere and there has been a significant increase in interest from Canada in this year’s Bermuda Captive Conference, according to organisers of the June event.The Island’s prospects for attracting captive business from Canada improved after the implementation of a tax information exchange agreement (TIEA) with Canada that affords Bermuda many of the same tax advantages previously enjoyed only by countries which have a double-taxation treaty with Canada.In recent months, several captive industry participants have banded together to stage events in the Canadian cities of Toronto, Montreal, Calgary and Vancouver. The breakfast seminars were aimed at raising awareness of what advantages Canadian companies could gain from having a Bermuda captive.Turnouts were good, especially in the west where the big mining and oil companies are based, and now the aim is to press home the message and do some business at the conference.Peter Willitts, chairman of the Bermuda Captive Conference organising committee, said the industry realised Bermuda had more competition than ever in the captive space and had to fight for business.“There are now about 50 captive domiciles, so we’re no longer one of a handful,” Mr Willetts said in an interview. “So we have to get pretty aggressive about letting everyone know what we do. We have to do it well and do it quickly.”The conference will stage a breakfast event focused on Canada. RBC Wealth Management, an arm of the Royal Bank of Canada will be represented at the conference and is silver sponsor of the conference. In addition, a group of students will be attending the event from the University of Calgary.Barbados has traditionally been the domicile of choice for Canadian captives because of the double-taxation agreement between the two countries, a benefit that Bermuda had not been able to match until after the TIEA was implented last year.The TIEA earned Bermuda “designated treaty country status” under Canadian tax law. This allowed active business income earned by a Bermuda-based affiliate of a Canadian company to be included in exempt surplus. This means that dividends paid to the corporation by the affiliate are not subject to Canadian tax.The main focus of the marketing push is to attract new business, but some of the 200 or so exisiting Canadian captives in Barbados may also be considering Bermuda as an alternative.Vancouver-based mining company Teck was the first Canadian company to redomicile its captive insurer from Barbados to Bermuda last September. The energy giant Encana Corp followed suit.“The change in Canadian tax regulations puts us on par with other domiciles who have a tax treaty,” said PwC Bermuda director David Gibbons, an executive member of the Bermuda Captive Conference organising committee.“So then it comes down to seeing the major advantages of Bermuda as a domicile. We expected to see a lot of new formations and interest. It’s interesting that we are already seeing large companies with established captives moving domiciles.”Among those advantages are the cluster of service providers and expertise formed and built up over more than half a century of captive insurance business on the Island, the presence of the reinsurance industry here, and the fact that travelling to Bermuda is much easier and quicker for Canadians than travelling to the islands farther south.For more information on the Bermuda Captive Conference, visit the website at www.bermudacaptive.bm

David Gibbons