CRA Publishes Administrative Positions on Import Rules for Reinsurance Contracts for Financial Institutions

The Canada Revenue Agency (“CRA”) published GST/HST Notice No. 287 to discuss its administrative positions with respect to the application of the import rules to reinsurance premiums paid by insurers.  These views are applicable to insurers who are qualifying taxpayers under the import rules and are paying reinsurance premiums to non-resident reinsurers with whom they are not dealing at arm’s length.

The Notice includes the CRA’s administrative position on administrative expenses, the margin for risk transfer, commissions and expense allowances, and service level agreements.