Sunday, July 6, 2025

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GCP Short: Tax treatment & anticipating a UK Captive regime

Stephen Massey, Ernst & Young LLP
Richard Cutcher, Captive Intelligence

In this GCP Short, produced in partnership with the EY Global Captive Network, Richard is joined by London-based Stephen Massey, Senior Manager in EMEIA for Financial Services (Insurance) Tax – Transfer Pricing at Ernst & Young LLP, to discuss how the international tax treatment of captives has changed over the years.

Stephen and Richard also discuss the global tax environment for captives in the context of the UK likely becoming a captive domicile in the very near future.

Stephen explains some of the reasons why a UK companymoving its captive ‘home’ may be advantageous from a tax simplification and compliance standpoint, in some cases.

The UK Chancellor is expected to confirm the introduction of a UK captive regime in her Mansion House speech on 15 July, which should then prompt the Bank of England and PRA to get on with designing the regulatory framework to hopefully be ready for launch by early 2026 or sooner.

As ever we will be following this story closely on ⁠Captive Intelligence⁠ so do make sure you are visiting our website and signed up to our ⁠twice-weekly newsletter⁠.

The views expressed in this podcast are those of the individual and do not represent Ernst & Young LLP. The content is intended for general information only and is not being provided as tax advice – instead, listeners should contact their usual professional advisors for specific advice.