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HMRC internal manual

Insurance Premium Tax

HM Revenue & Customs
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Calculating the value of the premium: types of contract covering exempt and taxable risks: determining what is ‘just and reasonable’

By just and reasonable we mean that the result of the apportionment should be fair to both the insurer and to us. The insurer must be able to demonstrate that the apportionment was arrived at by a process of reasoning which took all relevant factors into account.