Corporate finance › Tax Opinion Liability

Tax Opinion Liability insurance protects the insured against an assessment to pay tax to a relevant authority where the assessment has been made during the limitation period following:

  • A merger or acquisition or listing on a Stock Exchange
  • Specific Tax planning in accordance with professional advice
  • A restructuring or reorganisation within one or more companies in the same group, also in accordance with professional advice.

Policy Cover

  • Assessment of tax due
  • Interest payments
  • Fines and Penalties
  • Costs and Penalties

Points to Note

This type of insurance is complex and will not cover certain aspects, notably:

  • Tax rate changes alone
  • Tax mitigation investment products
  • Limited partnerships of individuals
  • Transactions with no other commercial purpose than to create a tax advantage
  • Transactions already being reviewed by the tax authorities or where notice to review has been given