Insurance Europe raises base erosion and profit sharing concerns Insurance Europe recently raised concerns regarding the public discussion draft on base erosion and profit shifting (BEPS) by the Organisation for Economic Cooperation and Development’s (OECD) regarding strengthening controlled foreign company (CFC) rules. Insurance Europe emphasised that an insurance income in a different territory to the risk insured does not equate to BEPS activity taking place but rather this occurrence is a byproduct of the globalisation of insurers managing risks, including through reinsurance. They also stated that a clearly articulated policy objective is missing from the discussion draft which attempts to satisfy multiple competing objectives creating a set of complicated – and sometimes conflicting – proposals. Concerns were also highlighted about how the CFC proposals could potentially undermine the detailed work already done under other BEPS actions. Insurance Europe has suggested the development of the CFC to deal solely with BEPS issues, and nothing further.