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HMRC internal manual

Insurance Premium Tax

Liability of insurance contracts: Goods in foreign or international transit: Definition of

Premiums relating to contracts covering containers which carry goods in foreign or international transit are also exempt from IPT, provided the conditions in Paragraph 12(2) are met. It was thought inappropriate to exempt premiums relating to the international movement of goods whilst taxing the premiums relating to the containers, which facilitate the movement of those goods.

Paragraph 12(3) of Schedule 7A to the Finance Act 1994 gives “container” the same meaning as in:

… regulation 38(3) of the Value Added Tax (General) Regulations 1985.

Regulation 38(3) is now Value Added Tax Regulations 1995 (SI 1995/2518), regulation 117(2). This defines a container as:

… an article of transport equipment (lift-van, moveable tank or other similar structure)-

(a) fully or partially enclosed to constitute a compartment intended for containing goods;

(b) of a permanent character and accordingly strong enough to be suitable for repeated use;

(c) specially designed to facilitate the carriage of goods, by one or more modes of transport, without intermediate reloading;

(d) designed for ready handling, particularly when being transferred from one mode of transport to another;

(e) designed to be easy to fill and to empty; and

(f) having an internal volume of 1 cubic metre or more.