In the budget the Government announced that it will amend section 221 of the Finance Act to ensure regulations can be made to set out the tax treatment of Solvency II compliant capital instruments in advance of the agreement to Solvency II.  Subject to the outcome of the OECD’s base erosion and profit shifting project, the Government will make regulations to ensure that insurers’ Solvency II instruments which are issued in the form of debt are taxed as debt instruments as the tax treatment of these instruments is uncertain.  

Related link:

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/293759/37630_Budget_2014_Web_Accessible.pdf