Federal Excise Tax (FET) Exempt Insurers

The new UK/US tax Treaty came into effect on 1st January 2004, and UK companies will now have determined their best course of action particularly in relation to entering into a closing agreement with the Internal Revenue Service (IRS). A closing agreement will permit the IRS to audit books and records to evidence that there has been no FET avoidance (conduit arrangements) or FET liability.


It is not a condition precedent that a UK established company takes any action to be entitled to benefit from the treaty. A company can confirm in a written statement that they are an established UK company and entitled to benefit under the treaty. This course of action is being adopted by a limited number of companies. It is also available to those companies who have applied for a closing agreement but await finalisation by the IRS.



The following Ordinary and Affiliate IUA members have received a closing agreement under the US/UK Treaty:


Alea London Ltd

Allianz Cornhill Insurance Plc

Arch Insurance Company (Europe) Limited

Aspen Insurance UK Ltd

Catlin Insurance Company (UK) Ltd

CNA Insurance Company Limited

Endurance Worldwide Insurance

GE Frankona Reinsurance Ltd

GE Specialty Insurance (UK) Ltd

Great Lakes Reinsurance (UK) Plc

ING Re UK Ltd

International Insurance Company of Hannover Ltd

Liberty Mutual Insurance Europe

Markel International Insurance Company Ltd

QBE International Insurance Ltd

Royal & SunAlliance Insurance Plc

SCOR UK Company Ltd

SR International

Swiss Reinsurance UK Ltd

Tokio Marine Europe Insurance Limited

Tokio Marine Global Limited

Zurich Specialities London Ltd



The following IUA members are currently applying for a closing agreement:


Groupama Transport





The following IUA members have confirmed that they qualify for all of the benefits of the new UK-US Double Taxation Treaty (W8 Ben):


Ace European Group (previously Ace-INA) 

Chartis Insurance UK Limited

Chevanstell Ltd



The following IUA members are US companies or have confirmed to IUA and/or Lloyd’s that they are subject to other US double taxation treaties: 


Allianz Global Corporate & Specialty AG (closing agreement received)

Assicurazioni Generali S.p.A. (UK Branch)

AXA Corporate Solutions Assurances SA 

Everest Reinsurance Ltd

Federal Insurance Company

GE Frankona Ruckversicherungs Aktiengesellschaft

Hannover Re

Houston Casualty Company Ltd

Munich Reinsurance Company

New Hampshire Insurance Company

Sirius International Insurance Company (UK Branch) (closing agreement received)

Zurich Insurance Company (Swiss Company) (closing agreement received)

* to be confirmed



The following IUA members for 2004 have informed us that they are not affected and therefore are taking no action:


Chubb Insurance Company of Europe

Ecclesiastical Insurance Office Plc

Faraday Insurance Company

Global Aerospace Underwriting Managers (though consortium members may have applied)

New India Assurance Company Ltd

QBE Reinsurance (Europe) Ltd

XL Re


IUA has been in close contact with the London Market Brokers Committee (LMBC), the Council of Insurance Agents and Brokers (CIAB) and Lloyd’s on this matter. Lloyd’s itself has already entered into a closing agreement with the Internal Revenue Service (IRS).