Offshore Investment Bonds and Brexit

I've been starting to look at this... Most of the offshore investment bonds we write and manage are Dublin based with a few IOM from time to time (a mixture of Life Assurance and Capital Redemption). It seems that a lot hangs on how we leave the EU (deal/no deal) and whether this (https://gov.uk/government/publications/draft-financial-services-contracts-transitional-and-saving-provision-eu-exit-regulations-2019/the-financial-services-contracts-transitional-and-saving-provision-eu-exit-regulations-2019-explanatory-information) transitional legislation comes into effect in time or not. If it does... this annex sounds relevant https://gov.uk/government/publications/draft-financial-services-contracts-transitional-and-saving-provision-eu-exit-regulations-2019/annex-run-off-regime-for-eea-firms-that-currently-passport-into-the-uk-under-financial-services-and-markets-act-2000

It sounds like things are OK for 5 years as most contracts would have come to an end or could be moved to a UK entity. Contracts of Insurance (which would be these offshore bonds) has a longer run off of 15 years which could be extended.

As Ireland is in the EU it is affected. However IOM is a Crown Dependency of UK so it isn't. Suggests that IOM might be the way forward, but as a firm that uses our DFM permissions Dublin has been preferable due to the VAT exemption (which may or may not remain, but doesn't apply in IOM).

Does anyone have any thoughts/views/insights and/or is happy to share what they are thinking/doing as a firm? Keen to get a feel as to what the consensus is forming...

Thanks all

Dan

Chartered Financial Planner FPFS APP Chartered MCSI
Head of Technical at EQ Investors

Twitter: https://twitter.com/danatkinsonuk
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