4.—(1) Subject to paragraph (2), tax is payable at the rate of 10% on the commission and fee income derived by an approved insurance broker from the provision of insurance broking or advisory services to a specified person.
(2) However, tax is payable at the rate of 5% on the commission and fee income referred to in paragraph (1) if —
(a)
the commission and fee income is derived on or after 1 April 2013; and
(b)
the insurance broking or advisory services provided to the specified person relate to offshore qualifying specialised insurance risks.