Risk Management at a Time of Systemic Uncertainty: Transfer Pricing Implications of Intra-Group Reinsurance Quota Share Arrangements

Abstract

This study addresses an underexplored and highly topical area regarding the international tax implications of risk management, examining some core methodological questions surrounding the transfer pricing aspects of intra-group reinsurance in depth. The study first provides an overview of traditional property and casualty reinsurance risk transfer structures. It then focuses, in particular, on proportional quota share reinsurance arrangements in both external and intra-group settings. Additionally, it highlights the key entrepreneurial risk-taking functions in the insurance sector and examines potential transfer pricing remuneration methods for quota share reinsurance arrangements in intra-group transactions. The latter points are illustrated through case studies.