Tax treatment of co insurance apportionment requires lead insurer to pay tax on the entire insured premium before apportionment. Amendment inserts two Schedule III entries: (1) apportionment of co-insurance premium by the lead insurer to co-insurers is recognised as an activity provided the lead insurer pays central, State, Union territory and integrated tax on the entire premium paid by the insured; (2) services by an insurer to a reinsurer where ceding or reinsurance commission is deducted are recognised as taxable provided the reinsurer pays central, State, Union territory and integrated tax on the gross reinsurance premium payable by the insurer inclusive of such commission.