In an interview with Bloomberg, Chaucer's chief executive officer Bob Stuchbery has indicated that Chaucer will consider redomiciliation out of the UK this year, noting that he would much prefer that Chaucer remained in the UK under a more competitive corporation tax environment. Since 2006, a string of listed Lloyd's holding companies have left the UK: Omega, Hiscox, Kiln and Hardy moved to Bermuda, Brit to the Netherlands and Beazley has moved its incorporation to Jersey but its tax residence to Ireland.
Meanwhile, ACE moved its holding company from the Cayman Islands to Switzerland in 2008, while XL is moving its holding company from the Cayman Islands to Ireland. Willis moved its listed parent company from Bermuda to Ireland at the end of 2009. Swiss Re and Zurich have moved business out of FSA regulated subsidiaries into Luxembourg and Irish regulated companies.
Bucking the trend, Amlin emphasises its UK domiciled status on its website home page and, following discussions with HM Revenue and Customs, RSA chose to remain domiciled in the UK although it is to set up a reinsurance company in Ireland to reinsure all of its non-UK risks. Chubb and XL have transferred business out of Belgium and Ireland, respectively, to UK subsidiaries.
It is apparent that among the redomiciliations there is no one jurisdiction to suit all groups or purposes. Although lower corporate tax rates combined with double taxation treaties are a key reason in some cases, regulatory consolidation and capital efficiency appear to be important factors in relation to operating company moves and no single jurisdiction appears to satisfy all of those reasons. However, for UK resident companies, the result of the UK general election (likely to be on 6 May this year) and the implementation of Solvency II at the end of 2012, may trigger a re-evaluation of the situation.