Tax Strategy

MS Amlin is part of MS&AD Insurance Group Holdings Inc and has material operations in the UK, Continental Europe and Bermudian markets.  MS Amlin operates in both the Lloyd’s and non-Lloyd’s markets. 

MS Amlin’s tax strategy is

  • To satisfy all tax compliance obligations within the relevant statutory timeframe and in compliance with the relevant tax law, disclosure requirements and regulations; 
  • To complete accurate tax reporting on at least a quarterly basis to allow a detailed understanding of MS Amlin’s effective tax rates as well as the tax balances in the balance sheet; 
  • To develop and maintain good working relationships with all tax authorities in jurisdictions where MS Amlin has a legal presence and with other external stakeholders including regulatory authorities; 
  • To contribute to shareholder returns on a sustainable basis by organising its tax affairs efficiently within the letter, and spirit, of the laws of the territories in which it operates; and
  • To ensure the internal tax teams (currently in ABS and MS Amlin AG)are pro-actively involved in developing tax legislation and lobbying for changes that promote both the interests of MS Amlin and the wider Insurance/Reinsurance industry.

MS Amlin seeks to safeguard shareholder interests as well as maintain its integrity, reputation and brand with its external stakeholders including investors, governments and customers at all times. 

Management of tax risks

MS Amlin faces similar tax risks to all multinational groups operating in the insurance market including cross border tax risks

  • MS Amlin operates a system of tax risk assessment and has appropriate controls in place to ensure tax risks are identified and mitigated in a timely fashion. The internal tax teams assess quarterly whether the controls are functioning effectively and whether the designs are fit for purpose.
  • The ABS tax team has corporate tax compliance and advisory, VAT and employment tax specialists in the UK to ensure all applicable tax risks are identified and appropriate action taken by skilled members of staff. ABS Tax staff are appropriately trained and there is focus on continuous development of tax knowledge. 
  • In other non-UK jurisdictions, the internal tax teams will engage external advisors to prepare and submit all tax returns.  No tax returns or payments will be filed without prior approval from the internal tax teams.
  • The internal tax teams work with the business to educate staff about the importance of involving the internal tax team before undertaking commercial transactions, to ensure any tax risks are identified and appropriately dealt with.
  • The Board of MS Amlin companies have oversight on tax matters and are briefed on key tax developments and tax impacts of commercial transactions when deemed appropriate by the Head of Tax. 
  • MS Amlin is committed to preventing persons associated with it from engaging in criminal facilitation of tax evasion and where possible, has procedures in place to identify and mitigate risks of facilitating tax evasion. 

Attitude to tax planning

MS Amlin’s policy is to pay the right amount of tax as required by local tax laws in each jurisdiction.

  • MS Amlin aims to undertake all tax planning within the context that the commercial needs of the company are paramount. However, where alternative routes exist to achieve the same commercial result, the most tax efficient route which is in line with and in the spirit of tax legislation should be recommended.
  • Managing tax efficiency involves choices as to the jurisdictions in which to locate capital and/or business activity and the legal structure of that activity. Such choices take account of all business and regulatory consequences of operating in such a manner. 
  • Where the MS Amlin internal tax team deems there is insufficient technical expertise within MS Amlin (for e.g. entry into a foreign market), external tax advice is sought.

Relationship with tax authorities

  • MS Amlin seeks to have a constructive and transparent relationship with all tax authorities through communication in respect of developments in MS Amlin’s business, current, future and retrospective tax risks, and interpretation of the law in relation to all relevant taxes. 
  • Where possible, tax authorities are regularly updated on significant business developments or matters that could involve a number of interpretations of tax legislation. 
  • Where relevant, MS Amlin discloses all uncertain tax positions and rationale for adopting treatments in the tax computations submitted to relevant tax authorities.

MS Amlin regards this strategy as complying with Schedule 19, Paragraph 16(2) of Finance Act 2016 for the year ending 31 December 2024.

This strategy is confirmed by MS&AD Insurance Group Holdings Inc.