Dear colleagues,

In the interests of ensuring ARC members are kept up to date with significant developments we are pleased to advise that an additional Breakfast Briefing has been scheduled for Wednesday 8th July 2009.

Last month, the German Advocate General delivered an opinion in a case concerning the transfer of contracts from Swiss Re Germany to another Swiss Re company in Switzerland. The Advocate General concluded that a sale of a portfolio of reinsurance contracts is not an exempt insurance or reinsurance transaction but is chargeable to VAT in the transferor's country.

If this opinion is followed by the European Court of Justice the consequences could be very serious and could imply that EU to EU or EU to non-EU portfolio transfers will be chargeable to VAT. Needless to say this could have a significant impact on business transfers in the legacy market and the restructuring of large insurance portfolios ahead of Solvency II.

We are pleased that Greg Sinfield, a partner at Lovells specialising in VAT and other indirect taxes, has agreed to address members on this matter at the briefing.

The presentation will commence at 9:30 with breakfast served from 9:00. Spaces are limited to 60 and are only open to ARC members - so hopefully you will have renewed your membership. If you wish to attend please register with This e-mail address is being protected from spam bots, you need JavaScript enabled to view it

Please also be reminded that we have another Breakfast Briefing the following week on 14th July with presentations from David Flandro of Guy Carpenter and Peter Hughes of Standard & Poors with booking also at This e-mail address is being protected from spam bots, you need JavaScript enabled to view it

Best Regards

Terry Dadds

Association Secretariat