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PENSIONS
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DOPTION OF THE THIRD LIFE DIRECTIVE in 1992
has led to the creation of a significant cross-
border European market in life assurance
business. Recent landmark judgments by
the European Court of Justice (ECJ) now at long last
presage the development of another cross-border
business for insurers, this time in the field of insured
pensions. The dismantling of national tax restrictions
is now becoming a reality and is expected to lead to
dramatic change in the European pensions landscape.
Ramstedt case
In a ruling laid down on 26 June 2003, the ECJ deliv-
ered a long-awaited judgment on a landmark test case
brought by the Swedish insurance company Skandia
on behalf of its director, Ola Ramstedt. Instead of the
usual Skandia Sweden pension arrangements, Mr Ram-
stedt had been offered pension policies from Skandia
UK, Skandia Denmark, and Skandia Germany. Unsur-
prisingly, the Swedish tax authorities refused deduc-
tion for the contributions paid to the foreign pension
providers, deeming the policies to be endowment
insurance rather than tax-preferred pensions. The case
was then referred to the ECJ by the Regeringsrätten
(the Supreme Administrative Court in Sweden).
Swedish legislation gives tax deductions to employ-
ers paying premiums to Swedish insurers, but denies
those benefits to employers paying premiums to
insurers based in other member states of the European
Union (EU). The ECJ ruled unambiguously after a
notably short period of deliberation that this is
incompatible with Article 49 (freedom to provide ser-
vices) of European Community law. The implications
of the ruling extend beyond Sweden, as many other
European countries currently apply similar tax dis-
criminatory rules that so far have frustrated the estab-
lishment of cross-border pensions.
Swedens attempted defence of the case, on the
grounds of fiscal cohesion of the national system, was
considered to be unconvincing. The court held that
the need to prevent the reduction of tax revenue is not
one of the grounds which would justify a reduction on
the freedom to provide services. Member states already
have three legitimate ways of safeguarding the taxa-
tion of pension benefits received by their residents:
u reporting by the individual taxpayer;
Cross-border pensions
Gary Boal warns insurers that markets in European cross-border pensions are about to explode.
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