自保业务要适用针对保险活动的税收规则,需要通过一定方法的测试而被认定为通常意义的保险。从国际上的税收实践来看,主要有两种判定方法:一是对交易主体进行测试,将独立法律实体间的自保交易视为保险;二是对交易性质进行测试,从交易所产生的经济后果出发,将符合某种标准而认为存在风险分散或风险转移属性的自保交易视为保险。 Self-insurance business to apply tax rules for insurance activities, the need to pass certain methods of testing is recognized as the usual meaning of insurance. From the perspective of tax practice in the world, there are mainly two kinds of judgments: one is to test the subject of transaction, treat the self-insurance transaction between independent legal entities as insurance; the other is to test the nature of the transaction and generate from the exchange For economic consequences, self-insurance transactions that meet certain criteria and that have the risk of diversification or risk transfer are considered as insurance.