Reinsurance Intra-Group Agreements – The Key Role of RE-EVA in Supporting the Arm’s Length Principle

Abstract

In an economic context in which risk management plays an important role for the economic players, it is increasingly common to come across reinsurance transactions. In this context, multinationals often make use of reinsurance agreements, generating significant transnational flows with the related consequences also in terms of transfer prices. Despite the efforts made by the OECD with the publication of the new chapter X of the OECD Transfer Pricing Guidelines and with the clarifications provided on risk analysis, the common transfer pricing rules are not immediately applicable to reinsurance operations, also due to the complexity of the agreements and the difficulty of applying the existing TP methods to them. Therefore, this article, having analysed the main transfer pricing risks associated with intercompany reinsurance transactions, intends to provide possible new tools to verify the compliance with the arm’s length principle of reinsurance agreements, such as the combined ratio, the capital release, actuarial analysis and the RE-EVA.