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Tax Committee – 12 March 2025

The Committee discussed recent audit themes, with a focus on Pillar 2 complexities, transfer pricing and the Bermudian DTA unwind. There was a detailed exchange on the challenges of deferred tax reporting under Pillar 2, particularly for mixed membership structures, and Lloyd’s will re-circulate modelling tools. Updates were also shared on Singapore allocations, Bermuda’s new tax authority and HMRC’s CIS response. The group debated the proposed withdrawal of the PE certification process, agreeing its value for market consistency. Lloyd’s provided updates on global tax systems, Canadian audits, VAT arrangements and US SIS process changes. The India tax position was also flagged for monitoring.