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Insurance industry alert to potential tax reforms

Tax talk: President Joe Biden is seeing to reform corporate tax for US companies, and his administration has shown support for a push by the OECD to create a minimum global corporate tax rate (Photograph by Evan Vucci/AP)

Companies in the insurance industry are keeping an eye on potential tax developments after US President Joe Biden's speech to a joint session of Congress, where he spoke about reforming corporate tax.

Mr Biden's administration is in favour of a US global corporate tax rate of 21 per cent. It has also shown support for a push by the Organisation for Economic Cooperation and Development to get countries to sign on to a minimum global corporate tax similar to the one proposed for US companies.

In an Associated Press report, Alexander Arnon, an analyst at research organisation Penn Wharton Budget Model, said a 21 per cent minimum global tax, if adopted, "effectively spells the end of the tax haven as we have come to know it".

Bloomberg reported that Pascal Saint-Amans, director of the centre for tax policy at the OECD, in the French senate on Wednesday, said: “Will Biden get to 21 per cent, or will it be a bit lower? We’ll see. As for the rest of the world, I doubt we’ll be at 21 per cent, but would we be at a rate nearing 21 per cent? I have good hope that is possible."

During this month's first quarter earnings season, financial analysts asked a number of re/insurers with Bermudian connections for their thoughts on possible changes to tax arrangements in the US and globally.

Answering a question about the impact of tax rates and potential changes to GILTI [global intangible low-taxed income] and BEAT [base erosion and anti-abuse tax], Kevin O'Donnell, chief executive officer of Bermudian-based RenaissanceRe, said: "There's a lot going on in various jurisdictions. I mean, you're looking at the US looking at rate increases, OECD is looking at some either through pillar one or pillar two, even the UK is looking at it.

"So it's going on a number of places that could impact us or not. I mean, we've been in Bermuda 25 years, and we feel pretty good about our position here. We've got the infrastructure here. We know it, and we like it. Relative to everywhere else it's much better. Now, we'll have to wait and see. We don't know what's going to happen. We're not going to plan, anticipate. We're not going to do anything in anticipation of it, but we'll keep an eye on it. We've got a global platform, and we've demonstrated in the past that we have the agility to be able to adjust and still retain the relative value that we have, and to offer to our shareholders.”

The impact of potential tax reforms was also raised during an earning conference call by Chubb Ltd, which is incorporated in Switzerland and has offices around the world, including in Bermuda.

In response, Evan Greenberg, chairman and chairman and CEO of Chubb, said: "I don't know enough. And we have both the corporate tax rate that could go up - they are talking 21 [per cent] going to 25 or 28, we'll see how that plays - and then, secondly, you've got GILTI and BEAT. And then you've got the notion of a minimum global tax rate multilateral agreement with OECD. All of these plates are spinning.

"The green book is not yet out. That would tell us any detail of what's in the tax reform for – the tax increase, heck, it's not a reform, proposal. And so we don't even know what the administration is yet proposing other than in headlines, and so we really can't speculate at this point. We just don't know. When it comes out, we'll have a better sense and then it's got to run the gauntlet in Congress and we'll see from there. I can't speculate at this point."

Executives at Bermudian-based Everest Re Group Ltd were asked for their view of discussions on corporate income tax rates going up, and particularly the GILTI tax.

Mark Kociancic, executive vice-president and group chief financial officer, responded: “It's premature to see how that's going to play out for us. But I don't think it’ll have a material impact on us in terms of the way we're organised. So I would expect it to be marginal if something like that is implemented in the fall.”

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Published May 07, 2021 at 8:01 am (Updated May 08, 2021 at 8:17 am)

Insurance industry alert to potential tax reforms

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