GLOBAL PROGRAMMES 2018 - COMPLIANCE OPTIMISE - AIG
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GLOBAL PROGRAMMES 2018 COMPLIANCE OPTIMISE OECD From the publishers of Collaborate to meet Consolidating (re)insurance Tackling the Beps regulation functions hurdle
FOREWORD
T
he expert contributors featured within the Captive Review Global Programmes
report are focused on guiding readers to best prepare for, and meet, the evolv-
ing challenges affecting large corporates and their insurance requirements.
With multinational business the norm, firms are tasked with raising the bar to en- REPORT EDITOR
Ross Law
sure regulatory compliance is met and to cater for increasingly sophisticated client +44 (0)20 7832 6535
demands. r.law@pageantmedia.com
CAPTIVE REVIEW EDITOR
Due to steadily decreasing premium rates, the insurance and reinsurance markets Richard Cutcher
are also beginning to change. With this rising pressure and the likelihood of greater +1 (646) 891 2133
r.cutcher@captivereview.com
consolidation, there is a growing desire for corporates to use their captives more
actively. GROUP HEAD OF CONTENT
Gwyn Roberts
As a result, enlisting a fronting partner capable of supporting captive managers
and owners through the likes of the OECD’s Base Erosion and Profit Shifting (Beps) HEAD OF PRODUCTION
Claudia Honerjager
regime, is becoming essential.
ART DIRECTOR
Elsewhere, the potential implications of the incoming IFRS 17 rule on captives are Jack Dougherty
outlined, along with the steps firms can take to ensure the wellbeing of their fre-
DESIGNER
quent-flying employees. Nadja Tschopp
We hope this report will give readers valuable insight into how best to structure and SUB-EDITORS
Luke Tuchscherer
manage their global programmes, maximise captive efficiency, and ensure multi- Alice Burton
jurisdictional compliance measures are met. Charlotte Sayers
PUBLISHING DIRECTOR
Ross Law, report editor Nick Morgan
+44 (0)20 7832 6635
n.morgan@captivereview.com
SENIOR PUBLISHING EXECUTIVE
Lucy Kingston
+44 (0)20 7832 6569
l.kingston@captivereview.com
DATA/CONTENT SALES
membership@captivereview.com
+44 (0)20 7832 6513
EVENTS MANAGER
Rachel Magnus
+44 (0)20 7832 6517
r.magnus@captivereview.com
HEAD OF EVENTS
Beth Hall
+44 (0)20 7832 6576
b.hall@captivereview.com
CEO
Charlie Kerr
Published by Pageant Media,
One London Wall, London, EC2Y 5EA
ISSN: 1757-1251 Printed by The Manson Group
© 2017 All rights reserved. No part of this publication
may be reproduced or used without prior permission
from the publisher.
3
CAPTIVE REVIEW | GLOBAL PROGRAMMES REPORT 2018
CONTENTS | GLOBAL PROGRAMMES
6 PROTECTING THE WELLBEING OF 14 THE CHANGING INSURANCE MARKET
EMPLOYEES OUT ON BUSINESS Paul Wöhrmann and Helene Westerlind, of Zurich,
MAXIS GBN reflects on the potential negative impact outline the benefits of having a fronting insurer
of business travel, and the practices and innovations
firms could implement to protect the wellbeing of their 16 GLOBAL PROGRAMMES: RAISING THE
employees BAR
Carol Barton, of AIG, describes the steps the firm is taking
9 ISSUES AND IMPLICATIONS FOR to enhance their global programmes service offering
CAPTIVES
Matthew Latham and Alex MacInnes, of XL Catlin, 18 SERVICE DIRECTORY
addresses the potential implications of the new IFRS 17
rule on captives
12 COMPLIANCE ACROSS BORDERS
Karen Jenner, of FiscalReps, discusses the need for clarity
in global programmes to ensure multi-jurisdictional
compliance needs are met
4
CAPTIVE REVIEW | GLOBAL PROGRAMMES REPORT 2018
Protection, delivered
seamlessly around
the globe.
Navigating a complex world can be challenging.
Wherever your business takes you, AIG is there to help you manage your risks with
confidence. Together, we take a proactive approach to build the optimal multinational
program that meets your needs today, and into the future. Refined over nearly a century—
you can count on our global perspective, local insights, and world class service to help
you simplify a complex world. Learn more at www.aig.com/multinational
Insurance and services provided by member companies of American International Group, Inc. Coverage may not be available in
all jurisdictions and is subject to actual policy language. For additional information, please visit our website at www.aig.com.
GLOBAL PROGRAMMES | MAXIS GBN
PROTECTING THE
WELLBEING OF
EMPLOYEES OUT
ON BUSINESS
MAXIS GBN reflects on the potential negative impact of business travel, and the practices and innovations
firms could implement to protect the wellbeing of their employees
B
usiness travel is often seen as and strategies to help improve diet and
glamorous and a perk of being activity while travelling.
successful in your career but the This could include encouraging employ-
reality – especially for employ- MAXIS GBN ees to explore alternative modes of trans-
ees who travel a lot – can be portation – such as taking the train instead
quite different. Indeed, frequent, and par- of flying. If there is no way around flying, it
ticularly long-haul business travel can have is preferable to fly direct instead of taking
a negative impact on a company’s most MAXIS Global Benefits Network (MAXIS GBN), connecting flights that will contribute to
co-founded by MetLife and AXA in 1998 is one of the
important asset: its people. tiredness and jet lag.
leading international employee benefits networks
It might still be considered essential for providing global service capabilities and delivering There may also be opportunities to
economic development and global trade, world-class employee benefits perspectives and solu- substitute face-to-face visits with telecon-
but the inexorable growth in business tions to clients in 115 markets around the world. For ferencing. Often it is necessary to meet
travel is leading to real questions about the more information, please visit www.maxis-gbn.com someone for the first time in person, but
health and wellbeing of the staff undertak- after that, video-conferencing can be an
ing the trips and the impact that frequent tion’. Other impacts can include psycho- acceptable substitute.
business travel has on both their mental logical, social and physical effects, includ-
and physical condition. ing accelerated ageing, and a heightened 2. Create a corporate travel policy
For these reasons, a broader company risk of stroke, heart attack and deep-vein As more and more people travel for busi-
consultation may be required when mak- thrombosis. ness, it is becoming increasingly important
ing corporate travel policy decisions. This So, what should international compa- from an HR and duty of care perspective
means, specifically, including HR and well- nies and, just as importantly, their staff do to consider the impact on staff wellbeing
being teams as well as the procurement and to try and reduce the negative effects of and health, not just in terms of the physical
travel management departments already frequent business travel? Part of the chal- impact of long-distance travelling but also
involved in managing business travel pro- lenge is that the requirements for each the mental and emotional aspects such as
grammes and policies today. person will differ depending on variables being away from family and normal rou-
It is frequent long-haul air travel, in such as number of trips, length of stays, tines.
particular, that is now understood to have distance travelled and other factors such as With corporate travel having a signif-
greater detrimental effects on staff than an employee’s family status (having young icant impact on employees’ wellbeing,
previously realised. And while jet lag is the children, for instance) so a single cover all morale and productivity, it is critical the HR
most commonly cited physiological impact solution won’t help. department be involved in the process of
of frequent business travel, it is not widely developing a company’s travel programme.
realised that the condition can persist for Here are some suggested steps employers They can make sure that duty of care pol-
up to six days after flying. Nor is it under- can take: icies reflect the changing global sentiment
stood that fatigue from jet lag, combined 1. Help employees to help themselves towards business travel and the pressures
with travel stress, may turn chronic and has Companies can look into employee educa- that can result.
been termed ‘frequent traveller exhaus- tion programmes on stress management HR departments can also help to boost
6
CAPTIVE REVIEW | GLOBAL PROGRAMMES REPORT 2018
MAXIS GBN | GLOBAL PROGRAMMES
can ‘combine virtual and augmented
reality into one experience’ and that
everyone in a business meeting can sit
in the same room together, no matter
where they are physically located. Par-
ticipants can even share virtual white-
boards. Could the VR headset be the
technology that finally replaces business
travel?
5. Revisit work conditions
As well as looking at overall travel wellness
programmes, organisations can consider
amending working terms and conditions.
Bearing in mind the fact that jet lag can
affect travellers for six days, organisations
could also allow staff to work from home,
offer more flexible hours following a
long-distance business travel trip, or space
out long-distance trips around minimum
rest periods. This way a frequent traveller
can also avoid the stresses that a lack of
productivity by influencing the organi- making it easier to take part in meetings, family time can induce.
sation to create policies that enhance the events, conferences, discussions and even Finally, employers should establish
traveller experience and reduce stress. For pitches, virtually – and it is expected that guidelines whereby employees would be
example, if employees are often required this focus will intensify as digital capabili- allowed to fly business class on long-haul
to travel on weekends, HR may work to cre- ties continue to improve. trips or book first class seats on trains when
ate a policy that allows travellers to extend A recent report on the BBC looked at travel time exceeds five hours.
their stay for a few days after completing some of the new technologies focused on
their work and enjoy some leisure time at making travel less stressful. From hotel 6. Manage travel risk
their destination. concierge services offering online check-in The events of 9/11 acted as the catalyst for
and room service at the touch of a button, introducing many standard travel risk pro-
3. Create a travel wellness programme to wireless Bluetooth padlocks for luggage, cedures today, such as systematic traveller
A travel wellness programme needs to focus tech innovations are being developed at tracking.
on specific environments that physically quite a pace – including in the exciting area Over half (51%) of companies provide
impact employees by encouraging certain of artificial intelligence (AI). no traveller safety or travel risk training to
less healthy behaviours: unhealthy eating • Teleconferencing solutions their employees.
choices and getting limited quality sleep. Teleconferencing solutions and other
These and other behaviours all increase remote technologies increasingly offer Evidence suggests that using business travel
the average physical stress load individuals companies, their employees and HR to meet face-to-face definitely results in a
would experience under normal working departments a workable alternative to net positive for multinational companies,
conditions. business travel. but we cannot ignore the science that tells
A travel wellness programme can us there can also be losses in the long term
include advice on eating healthily when • Instant translations if all too frequent travel has a negative
travelling, taking the right exercise, healthy Many well-known companies are work- impact on their employees’ health and pro-
flying, sleep and general stress manage- ing hard to perfect instant translation ductivity.
ment. Companies can also consider book- software that removes the need for Frequent, long-haul and lengthy peri-
ing rooms with hotel chains that have costly human translators and that means ods of business travel have been shown
gyms, and provide rewards for employees more international meetings may be to increase the risk of a variety of mental
who exercise while travelling. possible via video-conference or phone. and physical health problems, as well as
Combine instant translation with virtual exposing employees to security and safety
4. Use the power of technology reality and AI and there may soon be no problems. Unhealthy, tired and stressed
Advancements in technology and the devel- reason to take an international business employees who lack free time, rest periods
opment of new communications platforms trip ever again. and time for a personal life will ultimately
and solutions are giving business travellers affect a company’s bottom line.
and corporations more options when it • Virtual reality in video-conferencing To read more on this subject, down-
comes to long-distance communication. According to a leading multinational load our Whitepaper ‘BUSINESS TRAVEL –
Huge investments are being made by some technology company, wearing a virtual GOOD FOR BUSINESS, BAD FOR HEALTH?’
of the world’s leading technology firms in reality (VR) headset means participants at maxis-gbn.com
7
CAPTIVE REVIEW | GLOBAL PROGRAMMES REPORT 2018
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XL CATLIN | GLOBAL PROGRAMMES
ISSUES AND
IMPLICATIONS FOR
CAPTIVES
Matthew Latham and Alex MacInnes, of XL Catlin, addresses the potential implications of the
new IFRS 17 rule on captives
I
nsurance buyers, investors and analysts including – notably for captive owners –
have long noted the challenges involved Bermuda and the Cayman Islands. IFRS 17
in comparing insurers’ results. This is would therefore not be relevant in these
particularly the case with insurers that Matthew Latham circumstances.
are not required to report their finan- Companies in many other jurisdictions
cials using US GAAP. are obligated or allowed to report their
Among this set of insurers, there is con- Matthew Latham is XL Catlin’s head of captive pro- results using IFRS. IFRS is used in over 100
siderable variation between companies on grammes, international P&C. He is based in London jurisdictions globally, including the Euro-
and can be reached at matthew.latham@xlcatlin.com
how they measure profitability, account pean Union, Canada and Australia as well
for different types of expenses and con- as parts of Asia, South America and Africa.
solidate country-level data. Our assessment is that IFRS 17 will affect
In response, IFRS 17 was developed captives domiciled in jurisdictions where
to create a common global insurance Alex MacInnes local laws/regulations require that IFRS
accounting standard that will make it be used for entity-level reporting. For
easier for insurance buyers, investors example, a captive domiciled in Malta and
and analysts to understand and compare owned by a US-listed group may need to
Alex MacInnes, XL Catlin’s head of finance, financial
insurers’ results. It achieves this by pre- reporting & accounting, provided valuable support in
follow IFRS 17 under Maltese reporting
scribing a standard accounting method preparing this article. requirements, even though IFRS is not
for valuing insurance contracts. applicable to the listed group accounts.
The International Accounting Stand- meet the needs of regulatory/tax author- However, another captive, domiciled in
ards Board (IASB) released this new rule ities; although it notes that they could Bermuda and owned by a Spanish-listed
in May 2017. It will apply for accounting benefit from the way certain information group, most likely would not have to apply
periods starting on or after 1 January 2021, is reported on a balance sheet. IFRS 17 for local-entity reporting, since
although companies can implement it The absence of any discussion of the Bermudian insurance companies are not
before then. effect of IFRS on captives is perhaps not required to use IFRS.
surprising since, in our view, it likely will We also believe that, in most cases, the
Implications for captives: what does this have no direct impact on many if not most parent company would not need to mod-
mean for captive insurance companies? captives. ify significantly its IFRS group accounts
In all of the material published so far Nonetheless, for those captives where it to conform to IFRS 17, since a captive’s
about IFRS 17, there is no mention of cap- applies, IFRS 17 could be time and resource transactions and balances are typically not
tives. An “effects analysis” prepared by the intensive due to the heavy operational material to the overall group – although
IASB, for instance, focuses primarily on burden of implementing the standard rel- the company would need to agree on this
“listed insurance companies”. ative to the size of the captive entity. materiality assessment with its auditors.
The absence of any discussion on cap-
tives could relate to the fact that the pri- Some context What you need to know if your captive is
mary objective of IFRS 17 – making it easier Companies listed in the US, apart from required to use IFRS 17
to compare insurers’ results – is not rele- certain foreign corporations, are required The following is intended to outline only
vant to captives. to report their results using US GAAP. Since the most salient provisions of IFRS 17.
Moreover, the IASB explicitly acknowl- US GAAP is widely used and understood, However, if your captive will be affected,
edges that IFRS 17 was not developed to it is also permitted in other jurisdictions we suggest that captive managers con-
9
CAPTIVE REVIEW | GLOBAL PROGRAMMES REPORT 2018
GLOBAL PROGRAMMES | XL CATLIN
sult with their accounting/audit partners claims have been incurred, and the - changing the presentation of perfor-
about the specific ramifications of this CSM is not calculated at all. mance in the profit and loss account.
new rule on their operations.
Here’s where it starts to get technical: • IFRS 17 also requires the company to In summary, the impact of IFRS 17 on
• IFRS 17 applies to insurance contracts distinguish between groups of con- captives that are required to use it will
as opposed to entities; it also covers tracts expected to be profitable and largely depend on the nature of the con-
reinsurance contracts that are held by groups of contracts projected to be tracts involved. Short-duration, short-tail
a company. loss making. Expected losses are rec- contracts are likely to be least affected,
ognised in profit or loss immediately. partly due to the simplified approach
• It prescribes a standard accounting available for short-duration contracts,
method for valuing contracts and and partly because the discounting and
also stipulates that contracts carried “For those captives risk margin adjustments are likely to be
as assets be presented separately on less material.
balance sheets from those carried as where it applies, IFRS 17 Also, there is no specific guidance on
liabilities. how non-standard solutions like mul-
could be time and ti-line/multi-year contracts are to be
• Insurance contracts, whether car- reported under IFRS 17. This is an issue
ried as assets or liabilities, are to be resource intensive” that warrants further discussions with
reported as the total of the: fulfil- the IASB as the practical impact of split-
ment cashflows – that’s the current ting multiple risks incorporated into a
estimate of the amounts the company Captives that are affected by this new rule single contract, particularly where a CSM
expects to collect from premiums are most likely using IFRS 4 currently. Com- is required, could be problematic.
and pay out for claims, benefits and pared to IFRS 4, some of the most significant XL Catlin is currently assessing how
expenses, including an adjustment for new requirements in IFRS 17 call for: and where IFRS 17 will impact its local
the timing and risk of those amounts; - including extensive – and potentially operations. As we learn more about this
and contractual service margin (CSM) burdensome – additional informa- new accounting standard, we will also be
– the expected profit over time as the tion in the financial statements about cognizant of the potential impacts on our
insurance coverage is provided; claims liabilities, changes in risk and clients and especially our captive clients.
the effects of discounting; As new issues and implications are uncov-
• For certain contracts – including - discounting the liability for claims ered, we will continue to share our obser-
those with coverage terms less than and including an explicit risk adjust- vations with the captive community.
12 months – a simplified approach can ment when measuring it;
be used. With this method, fulfilment - recognising profits using the contractual Source: IFRS Standards, Effects Analysis, IFRS 17, Insur-
cashflows are not calculated until service margin, where required; and ance Contracts
10
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GLOBAL PROGRAMMES | FISCALREPS
COMPLIANCE
ACROSS BORDERS
Karen Jenner, of FiscalReps, discusses the need for clarity in global programmes to ensure
multi-jurisdictional compliance needs are met
A
s increasing focus on global risk which is exempt from IPT) as: “…such
insurance programmes and amount as, with the addition of the tax
ensuring compliance con- chargeable, is equal to the amount of the
tinues, there is often a lack Karen Jenner premium”. In practice, this means that
of understanding or clarity HRMC view the gross premium to include
on who is responsible for overall compli- tax regardless of whether it is split out on
ance. In theory much onus is placed on the Karen Jenner is client director at FiscalReps. She the invoice. In Germany, however, should
insurance company, however in practice joined the company as an insurance consultant the invoice not separately identify the
and has over 25 years of experience in the insur-
the onus of Insurance Premium Tax (IPT) premium tax, the authorities may view
ance industry. She is ACII qualified and has held
compliance and filing of other indirect previous roles with AIG and Willis. Jenner provides the total premium charged to be net, and
insurance taxes falls on various parties, invaluable global technical insurance guidance to charge tax on this full amount.
depending on the type of taxes due and FiscalReps through her experience of global insur- This is the most common regime for
territories involved. ance programmes and non-conventional insurance. domestic and licensed insurance business,
Aside from who is accountable, there and outside the EU is applied to Goods and
are varying and different requirements separately identifying the premium tax Services Tax (GST) on insurance premiums
around calculation and invoicing which from the risk premium, and the insurer in Australia and New Zealand, premium
are key to ensuring full compliance on any then deducting the tax from the payment taxes in California, and also in South Africa
global insurance programme. received for onwards settlement to the for the purpose of calculating VAT.
In considering who should ‘pay’ the tax, authorities.
we are confronted with two key parties: Insurer borne tax
the tax debtor – the party who bears the Here the insurer is expected to bear
economic cost of the tax – and the tax the economic cost of the tax, and is also
payment debtor – the party responsible “There is often a responsible for filing and settlement to
for filing returns and settling taxes with
the authorities.
misconception that the authorities. The insurer should gen-
erally not invoice the tax to the insured,
Regardless of who bears the economic intermediaries do not but must deduct this amount from the
cost of the tax, the responsibilities of risk premium invoiced to the insured
the tax payment debtor can fall to vari- have any liabilities for filing and settlement. Generally, in
ous parties to the global insurance pro- this model the tax is not calculated on
gramme: arising from taxes a per policy basis, but across all risks
• Insurer on the insurer’s book of business over a
• Policyholder on global insurance fixed period. While many insurers gross
• Insured
• Intermediary or broker
programmes” up risk premiums to factor this addi-
tional cost in the total premium cost,
• Fiscal representative the insurer should not itemise the tax
amount on any policy documents or
Traditional indirect tax Although simple, the traditional model invoices. Examples of this regime are more
In this model the tax debtor is generally can cause some issues around the calcula- common in Europe, and are applied to IPT
the policyholder, with the tax payment tion method as, even across the EU, differ- in Hungary and the Non-Life Insurance
debtor being the insurer, with tax invoiced ent tax authorities look for different cal- Levy in Slovakia.
in addition to the risk premium. Responsi- culation models. In the UK Section 50(2),
bility for calculating, collecting and settling FA 1994 describes the chargeable amount Cross border
the tax falls to the insurer, with the invoice (where no part of a premium relates to a For cross-territory insurance, not includ-
12
CAPTIVE REVIEW | GLOBAL PROGRAMMES REPORT 2018FISCALREPS | GLOBAL PROGRAMMES
and paying to the authorities, in addition
to the full amount of premium invoiced by
the insurer.
It is important to consider whether the
recipient of the supply is GST/VAT regis-
tered and whether the transaction is B2B or
B2C. Other issues with this model include
understanding the place of supply rules for
services. Where the policyholder is respon-
sible for settlement, the administration is
fairly simple, with any reverse charge being
added to their period GST/VAT return. The
taxpayer may be able to recover the tax if
they are making taxable supplies.
Other parties
In global programmes where the insurer is
ing Freedom of Services (FoS), the onus in making tax declarations, communica- liable to account for the tax, the question of
of collection and settlement of indirect tions with the taxpayer, and legal juris- co-insurance arises. Unfortunately, there
taxes tends to fall on the policyholder, or diction failing to be applicable to overseas is not always a consistent approach as to
an insurer’s agent or fiscal representative. taxpayers. whether it is the lead insurer, or the lead
As ever, where there is a rule, there is an The more common result of writing and follow who are responsible for taxes.
exception: in the UK, the responsibility to non-admitted business is for a tax regime In the UK, HMRC expect each co-insurer to
make declarations on insurance under- to apply to the insurance buyer i.e. local account for IPT on their share of the risk,
written overseas remains with the insurer. insured. In these regimes the ultimate whereas in the Netherlands, the lead may
In some territories a fiscal representative is policyholder can find themself liable for account for the full tax if certain condi-
required to settle taxes on behalf of over- Income or Withholding taxes, Goods and tions are met (including the absence of a
seas insurers writing on a cross border Services tax, VAT and Stamp Duties. taxable intermediary). In France, the lead
basis. A fiscal representative is a person or is expected to account for the full IPT on a
company resident in the country of taxa- Withholding taxes contract, whereas in Germany, one EU/EEA
tion who agrees to accept joint and several Where withholding taxes apply to co-insurer can be nominated, in writing,
liabilities, together with the taxpayer, for cross-border insurance, the tax debtor is by other co-insurers to account for full IPT.
the payment of taxes due. These are legal commonly the insurer, and the tax pay- In many more countries, the law is silent.
appointments and differ from tax agency, ment debtor role falls to the policyholder, There is often a misconception that
and are a voluntary arrangement governed responsible for calculating the tax, (not evi- intermediaries do not have any liabilities
by a contract between the insurer and denced on policy documents or invoices) arising from taxes on global insurance pro-
agent. and then for deducting and withholding grammes. This is not the case. In Europe,
The fiscal representative takes responsi- the tax from the invoiced amount and set- in the UK, fees charged by an intermedi-
bility for filing all tax returns and payments tling to the authorities. With no obligation ary on policies subject to the higher rate
due on behalf of the insurer and can be a to the insurer the policyholder needs to be of IPT must be settled by the intermediary.
connected person. A captive may choose aware of the tax regime in existence and In the Netherlands, local intermediaries
to appoint a local subsidiary to act as fiscal its operation. The insurer cannot be pur- tend to be the default taxpayer, not the
representative. Other insurers may utilise sued for unpaid amounts and therefore insurer. Outside of Europe, in Australia
their own branch network, though many has no legal requirement to be aware of the where non-admitted business is written
appoint a formal independent fiscal repre- impact on their premium. This can lead to via an authorised agent in Australia, the
sentative. uncompetitive pricing in writing non-ad- agent assumes responsibility for premium
The requirement to appoint a fiscal rep- mitted business, as the insurer may choose tax compliance. In Germany, an agent
resentative has decreased over recent years to gross up premiums to avoid eroding with residence in the EU/EEA is authorised
for FoS business as it is seen to conflict with technical underwriting premiums. to receive insurance premium and take
EU principles. However a few territories It may be possible to mitigate, avoid or responsibility for premium tax settlement
still uphold this requirement (Cyprus and recover tax due depending on the terms of if authority has been delegated in writing.
Greece). Aside from FoS business there are any double tax treaty in force between the In conclusion, it is important that all par-
some notable countries where a fiscal rep- territory of the non-resident insurer and ties involved in a global programme be
resentative is required for other cross-bor- the territory of taxation. aware of who was primarily responsible
der insurance, including the Netherlands, for the compliance and the hierarchies
Denmark and Finland. This requirement GST/VAT – reverse charge in place. If tax authorities are not able to
has historically resulted from the insurer Here the roles of the tax debtor and tax recover from the tax payment debtor in the
not having a presence in the territory of the payment debtor fall to the policyholder first instance, the law often provides them
tax liability, therefore creating difficulties who is responsible for calculating the tax with the right to pursue other parties.
13
CAPTIVE REVIEW | GLOBAL PROGRAMMES REPORT 2018GLOBAL PROGRAMMES | ZURICH
THE CHANGING
INSURANCE MARKET
Paul Wöhrmann and Helene Westerlind, of Zurich, outline the benefits of having a fronting insurer
C
urrently the entire insurance now better informed about their risks and
and reinsurance market is in keep the captive share on net. These own-
a state of great change, and ers ask for cross-class balance sheet pro-
over time could become even Helene Westerlind tection (see further Wöhrmann/Cunning-
more consolidated, because the ham) which can include the reinsurance of
industry is under rising pressure. This is Employee Benefit programmes.
largely due to the steadily decreasing pre- Helene Westerlind joined Zurich Insurance in Stock- On the other hand captive owners move
mium rates leading to lower margins while holm, Sweden in 2003 as a liability claims adjuster from a non-proportional to a proportional
and subsequently moved into liability underwriting
additional capacity is entering from the reinsurance structure in order to capture
where she was responsible for both domestic and
financial market. international programme business. Westerlind was the entire arbitrage market potential by
Interestingly, we have experienced these appointed into her current role as global head of accessing the reinsurance, retrocession
trends in our current competitive mar- International Program Business for Commercial Insur- and ILS market (Amar/Braun/Eling).
ance in 2016 managing a global team of 200 FTEs
ket environment. We are seeing that large Fronting insurers are then faced with
and responsible for the international customers of
European captive owners are using their commercial Insurance. complex customer service expectations,
captives more actively (Wöhrmann/Ruof) especially if the fronting insurer is also
in order to: acting behind the captive on a retroces-
- optimise insurance and reinsurance sion panel. Such risk transfer levels require
structures proven IT interfaces between the retroces-
- bring two worlds (life and non-life) Paul Wöhrmann sion, reinsurance and insurance level.
into one reinsurance captive Therefore, it is vital that captive owners
- benefit from arbitrage opportunities select a well-rated and reliable corporate
in the markets (pricing, coverage and Paul Wöhrmann, head of Captive Services Europe, insurer capable of paying and servicing
capacity) Middle-East, Africa, Asia Pacific and Latin America, claims, which are ultimately reinsured to
- strengthen the core business of the has developed a reputation as one of the world’s lead- the captive.
captive owner ing authorities on captive strategy and was ranked Zurich has the experience required
the third most influential person in the industry by
- develop solutions for new risks to manage such complex captive owner
Captive Review in 2016. He has been with Zurich for
As a consequence, larger internationally more than 25 years and leads a team of experts which requirements on a global scale and captive
operating industrial captive owners need is located in four countries across the world. owners can expect comprehensive support
highly experienced insurance companies that is consistent, end-to-end and world-
as fronting partners, to allow them effi- the financial incentive for captive own- wide (see Captive Related Services operates
cient access to the reinsurance market (see ers to influence future frequency claims across all geographies, underwriting pro-
Common Single Parent Reinsurance Cap- through active risk management and the cess and Zurich Group, p. 15).
tive Structures, p. 15). systematic identification, assessment and Zurich can provide their captive cus-
Having a captive on board allows their improvement of risk. As a consequence, tomers with so-called “captive health
owners to optimise pricing, coverage and the cost of risks can be reduced, and prof- checks” (Webinar) as a separate service.
capacity strategies across the insurance itability will be protected by introducing The individual captive retention is bench-
cycle. appropriate risk control measures, which marked across the same industry by actu-
Large European captive owners have reduce future claim frequencies and the arial methodologies. Zurich’s comprehen-
successfully started to follow such a strate- cost of premiums (Krause/Wöhrmann). sive data makes such analysis possible and
gic approach under a holistic view (life and Despite the soft market development, provides added value for captive customers
non-life/ see further Wöhrmann/Marini). we have observed that within the portfolios using this service.
In the past, the majority of captive rein- of our captive customers, there has been a Furthermore, captive owners should
surance programmes were reinsured by more active use of reinsurance captives – consider selecting one strategic insurance
fronting insurers on a non-proportional especially for large captive owners. fronting partner that can operate wherever
basis within primary layers. This is due to On the one hand, captive owners are the customer has a presence, someone who
14
CAPTIVE REVIEW | GLOBAL PROGRAMMES REPORT 2018ZURICH | GLOBAL PROGRAMMES
can cope with the increasingly complex
regulatory and tax landscape. An exam-
ple of such an increase in tax complexity
is OECD’s Base Erosion and Profit Shifting
(Beps) initiative, which may make it nec-
essary for captive owners to review their
captive set-up from a tax perspective (see
further D. San Millan and D.J. Kusaila).
An effective and professional captive
fronting partner should be able to:
• simplify management across lines of
business
• solve complex insurance problems
• access a strong and reliable global net-
work
• address insurance premium tax com-
pliance for captive programmes
• provide accurate, transparent and
timely bordereaux reporting through a
single ceding party
Customers who consider a change
in their buying behaviour for arbitrage
requirements, need an insurance partner
with a specific proposition to meet their
needs. This partner should be able to deal
with the new and growing demand by
reinsurance captives to leverage tangible
benefits of portfolio diversification and to
ensure that capital requirements are met.
At Zurich, we see arbitrage in three differ-
ent categories where captive owners can
capture tangible benefits.
Firstly, pricing arbitrage especially for
medium and high excess layers between
the insurance, reinsurance and ILS market.
Secondly, coverage and wording arbi-
trage in order to issue tailor-made insur-
ance programmes, for example on cyber
risk with wordings that meet the captive
owner’s expectations. Captives would
accept insurance policy exclusions. Hence,
the wording of the insurance coverage
could be much broader than that of the
retrocession level behind the captive. In Conclusion work infrastructure available, for a fee,
other words, the captive would cover any The current market environment provides for more lines of business. Since the retro-
deviation. attractive and comprehensive risk self- cession level, in addition to the insurance
Finally, capacity arbitrage. Capacity financing and risk transfer solutions, programmes, is often an integral part of a
arbitrage has been experienced in the which could create persistent business captive’s involvement, insurers who can
banking and mining industry. Such a solu- opportunities for various market partici- serve in a customised manner, with trans-
tion generally requires substantial captive pants. Corporate insurers which operate parent premiums and claims information,
risk retention and attention for counter- globally might find they are increasingly will be prioritised as future partners of
party credit risk matters. asked by captive owners to keep their net- captive owners.
Quotes: S.B. Amar/A. Braun/M. Eling, Alternative Risk Transfer and Insurance-Linked Securities: Trends, Challenges and New Market Opportunities, Institute of Insurance Economics I.VW-HSG,
University of St. Gallen (2015)
P. Wöhrmann/A. Ruof: “What to look for in an insurer’s captive proposition”, in: Captive Review Magazine, October 2013, p. 44 f.
P. Wöhrmann/P. Marini: Captives come of age, in: Captive Review Solvency 2 Report, October 2014, page 6 f.
P. Wöhrmann/Jean-Pierre Krause: “Are you engineering your risks effectively”, in: Captive Review Magazine, March 2014, p. 46 f.
P. Wöhrmann/T. Cunningham: Efficiency and Profitability, in: Captive Review - Global Programme Report, edition October 2015, P. 14-15
D. San Millan: BEPS not a threat to captives if used correctly: San Millan, in: Commercial Risk Online on August 9, 2017 (http://www.commercialriskonline.com/beps-not-threat-captives-used-
correctly-san-millan)
D.J. Kusaila: How Will BEPS Affect Captive Insurance?, in: Captive Review February 2016, p. 23 f.
Webinar: How To Optimise Captive Underwriting, Captive Review January 26, 2017 (http://captivereview.com/features/webinar-how-to-optimise-captive-underwriting/)
15
CAPTIVE REVIEW | GLOBAL PROGRAMMES REPORT 2018GLOBAL PROGRAMMES | AIG
GLOBAL
PROGRAMMES:
RAISING THE BAR
Carol Barton, of AIG, describes the steps the firm is taking to enhance their global programmes service offering
A
s our new chief executive Brian Larger clients with captives can take a
Duperreault commits to a new more centralised approach to local risks
era of growth, AIG is respond- and benefit from geographical diversifica-
Carol Barton
ing to the increasingly sophis- tion. Of course, captives also enable access
ticated needs of its multina- Photo by Barbie Schwartz to reinsurance markets that would not be
tional client base. Carol Barton, president available at a small, local level. And, it’s not
Carol Barton is president of AIG Multinational. She is
of AIG Multinational, explains why AIG has responsible for the worldwide leadership and strate- just large clients who benefit; more and
been making significant investments in gic direction of AIG’s multinational business as well more middle-market companies expand-
people, process and technology in order as a number of assigned countries around the world. ing outside their borders are realising the
to set a new industry standard for delivery value of a global approach and are looking
of global programmes to help clients meet ing and have the potential to lead to some to their brokers and insurers to assist.
their risk, governance and contract cer- uncomfortable questions from the C-Suite As a result, our multinational business
tainty objectives. at the time of a major event. has been experiencing exponential growth
Many risk and insurance managers of in new clients and programmes year-on-
large corporates will be familiar with the Scaling up to meet the challenge year. The AIG Global Network comprised of
challenges around structuring optimal In an increasingly global and intercon- strong local country operations and strate-
compliant multinational programmes and nected world, the past decade has seen a gic network partners is committed to deliv-
then fulfilling regulatory requirements to steady shift towards multinational insur- ering world class expertise, solutions and
enable issuance of local policies. Policies ance programmes. And this is expected to service to clients in over 215 jurisdictions
can be days, weeks or even months late as continue, particularly with new growth in around the world.
multiple stakeholders chase after missing emerging markets. Forty per cent of For-
documentation. This leads to unnecessary tune’s Global 500 multinational companies Re-engineering the process
frustration and unintended and redundant are now headquartered in Asia Pacific, In a significant effort to reshape how mul-
costs at a time when efficiency is of utmost from only 24% in 2006. From an industry tinational business is conducted, AIG has
importance in today’s globally competitive sector perspective, financial services insti- spent the last two years reengineering the
landscape. Additionally, financial and reg- tutions are leading the charge, according to process in collaboration with our broker
ulatory risks associated with not having a research by Willis Towers Watson. partners and clients. And it is no mean
contract in place at coverage inception can For large global corporate insurance feat to deliver all policies within a multina-
have a devastating impact. What if there buyers, the benefits are clear. They maxim- tional programme by inception – whether
is a loss in the days following the effective ise global insurance capacity and minimise you have exposures in 10 countries or 100.
date and the wording has not materialised? cost, while maintaining centralised con- However, this has now been achieved on
What if the claim occurs in a country where trol over risk management and risk trans- multiple occasions through close collabo-
there is no coverage if the local policy has fer practices. And in an age of data and ration with all parties, including our bro-
not been accepted and signed? Will the automation, they allow organisations to ker partners and multinational clients.
insurer be able to adjust the claim locally? consolidate and analyse loss information, Last year, we rolled out a globally con-
Can the claim settlement be made locally? enabling them to strengthen resilience by sistent end-to-end process across the full
What penalties or fines may be incurred? identifying areas of weakness or potential breadth of AIG general insurance prod-
These are just some of the concerns vulnerability before they become an actual ucts delivered around the world. This new
arising from the traditional way of work- problem. approach shifts all of the key activities from
16
CAPTIVE REVIEW | GLOBAL PROGRAMMES REPORT 2018AIG | GLOBAL PROGRAMMES
after the effective date to well in advance pre-inception policy issuance. Our award-winning MN Xpress tool
of inception. Several months later, for the Another important part of the process enables the end-to-end process by stand-
first time in our company history, we were involves scenario planning and testing, sit- ardising and automating the workflow pro-
able to deliver all local policies for a major ting around a table with all parties – includ- cess for our clients’ programmes, however
multinational client before the effective ing claims handlers – to consider how global, however complex in nature. It pro-
date, ensuring full contract certainty. Now the programme would actually respond vides territorial information and key doc-
this is not something that can be achieved in the event of a major loss anywhere in umentation requirements upfront, rather
in isolation; it is very much a collaborative the world. Such exercises challenge risk than post-purchase. Customer require-
process that relies on following pre-estab- and insurance managers to think about ments are communicated at the quotation
lished timelines with effective stakeholder what limits they really need, whether they stage well in advance of binding.
communication, so roles and responsi- The myAIG Multinational Client Por-
bilities are clear. Additionally, significant tal offers clients instant insight into their
investments have been made in tech- controlled master programme and spe-
nology to deliver tools to both simplify “We have taken our cific policy details, such as key dates and
and efficiently manage the process and premium amounts. We have taken our
advanced timeline. portal a step further portal a step further than most, ensuring
It is truly encouraging to see both cli- it captures information at a highly gran-
ents and broker partners getting excited
than most, ensuring it ular level, allowing clients to download
about these capabilities and working
together; our goal of full contract cer-
captures information at policy documents and invoices and to
tap into robust business intelligence.
tainty at inception has now become a a highly granular level” Without these technology platforms
reality for multiple clients having pro- to enable our process we would fail to be
grammes across all of our products. competitive in a rapidly-growing mar-
Feedback has been extremely positive ket. And as is always the case, it is impor-
from those who have embarked on this require local policies or can replicate the tant to keep one eye on the future. Take our
journey. So much so that we are beginning master coverage everywhere. There is no blockchain pilot with IBM that successfully
to see contract certainty become an inte- one-size-fits-all, which is why it is essen- completed a multinational programme on
gral part of the renewal conversations with tial to understand the client’s risk appetite, behalf of Standard Chartered. The pio-
our multinational clients. For example, philosophy and multinational exposures. neering programme uses blockchain to
one company is currently restructuring its manage complex coverage across the UK,
financial lines programmes with the inten- Blockchain, automation and the missing link US, Singapore and Kenya for the bank, and
tion of placing part of it out of the London Investment in technology and analytics has is certainly indicative of further efficiencies
market. Part of the discussion as they went been the secret sauce in achieving contract that are likely to be brought to the process
through this was around who could deliver certainty for multinational programmes. in the future.
17
CAPTIVE REVIEW | GLOBAL PROGRAMMES REPORT 2018SERVICE DIRECTORY
AIG FRONTING AND CAPTIVE SERVICES
Salil Bhalla, email: salil.bhalla@aig.com, Tel: +44 (0)207 954 8492
58 Fenchurch Street, London EC3M 4AB
We offer a full range of fronting and captive services. Our Captive Management Services group provides captive advisory
and managment services regarding the feasibility, structuring, formation and overall management of captives, and offers
cell captive facilities. Our programs extend to all types of exposures and industries.
www.aig.com/frontingandcap- Disclosure: Insurance and services provided by member companies of American International Group, Inc. Coverage may not be available in all
tiveservices jurisdictions and is subject to actual policy language. For additional information, please visit our website at www.AIG.com.
© American International Group, Inc. All rights reserved.
EY LLP
Paul H. Phillips III, Partner, EY Global Captive Network Co-Leader, email: Paul.Phillips@ey.com, Tel: +1 214 754 3232
2323 Victory Avenue, Suite 2000, Dallas, TX 75219
EY takes a multidisciplinary approach in addressing the alternative risk market through the EY Captive Services Team. The
EY Captive Services Team provides technical knowledge and industry experience, paired with a holistic portfolio of service
offerings (including assurance, actuarial, risk management, tax consulting, transfer pricing and compliance services) to
help clients navigate the current environment, evaluate risk and risk financing structures, reduce expenses, maintain com-
www.ey.com pliance and use capital more effectively within their organizations.
FISCALREPS
Karen Jenner, email: Karen.Jenner@fiscalreps.com, Tel: +44 (0)207 036 8070
200 Fowler Avenue, Farnborough Business Park, Farnborough, Hampshire GU14 7JP
Established in 2003, FiscalReps is an independent specialist indirect tax consultancy and market leader in premium taxes
globally serving over 400 clients. It transfers over €500m in client funds to tax authorities and processes over 25,000 tax
returns annually.
From its UK head office, FiscalReps provides clients with a guaranteed single point of contact and provides four core ser-
www.fiscalreps.com vices: Outsourcing, Technology, Consulting and Training.
GENERALI EMPLOYEE BENEFITS
Simona Frisoli, email: marketing@geb.com, Tel: +32 2 537 27 60
Avenue Louise 149, Brussels - Belgium
The Generali Employee Benefits (GEB) Network is a strategic unit of the Generali Group and exclusively focused on provid-
ing employee benefits solutions for corporate clients.
With 50 years’ experience in supporting the success of its global clients, GEB is recognized as a leading employee benefits
provider. It operates the world’s largest network by bringing together the capabilities of over 120 countries to serve more
www.geb.com than 1,500 multinational companies.
MAXIS GLOBAL BENEFITS NETWORK
Farzana Akther, email: farzana.akther@maxis-gbn.com, Tel: +44 (0)20 3876 2921
1/F The Monument Building, 11 Monument Street, London, EC3R 8AF
Co-founded by MetLife and AXA, two of the biggest and most trusted insurance companies in the world, MAXIS Global
Benefits Network is a network of nearly 140 insurance companies in 115 markets combining local expertise with global
insight. Together, we help multinational employers deliver the employee benefits they need to care for their people and
www.maxis-gbn.com meet their strategic goals.
XL CATLIN
Matthew Latham, email: matthew.latham@xlcatlin.com, Tel: +44 (0)207 933 7203
20 Gracechurch Street, London, EC3V 0BG, United Kingdom
XL Catlin. From insurance to reinsurance, a changing world needs new answers. We’re here to find them.
We are one of the world’s largest providers of global commercial insurance programs with 30+ years of network manage-
ment experience. We lead more than 70% of the 3000+ global programs we participate in. We also help clients use, opti-
xlcatlin.com mize and modify their captive structures, allowing each captive to meet its strategic goals.
ZURICH INSURANCE COMPANY LTD
Dr. Paul Woehrmann, email: paul.woehrmann@zurich.com, Tel: +41 (0) 44 628 82 82
Austrasse 46, 8045 Zurich, Switzerland
Zurich Insurance Group (Zurich) is a leading multi-line insurer that serves its customers in global and local markets. With more
than 55,000 employees, it provides a wide range of general insurance and life insurance products and services. Zurich’s custom-
ers include individuals, small businesses, and mid-sized and large companies, including multinational corporations, in more
than 170 countries. The Group is headquartered in Zurich, Switzerland, where it was founded in 1872. The holding company,
Zurich Insurance Group Ltd (ZURN), is listed on the SIX Swiss Exchange and has a level I American Depositary Receipt (ZURVY)
www.zurich.com/captives program, which is traded over-the-counter on OTCQX. Further information about Zurich is available at www.zurich.com.
18
CAPTIVE REVIEW | GLOBAL PROGRAMMES REPORT 2018WANT A CAPTIVE PARTNER THAT CELEBRATES YOUR BUSINESS AS MUCH AS YOU DO? LET’S TALK. When it comes to choosing a partner for your Captive programme, you’ll want one that has been awarded not just for its own success, but the success it brings to a client’s business. By combining global and local expertise, we can give you a solution that meets your individual needs, and together build a Captive programme everyone can raise a glass to. xlcatlin.com XL Catlin, the XL Catlin logo and Make Your World Go are trademarks of XL Group Ltd companies. XL Catlin is the global brand used by XL Group Ltd’s (re)insurance subsidiaries.
Road to the top
is full of risks —
to be ahead,
plan ahead
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