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HMRC internal manual

Insurance Premium Tax

Calculating the value of the premium: types of contract covering exempt and taxable risks: business with no non-UK establishment

You may find that insurers writing a policy for an insured with only UK establishments will maintain that the related premium should be apportioned to reflect the fact that the insured has an ‘exposure’ abroad. For example, if the insured has a world-wide product liability policy but only a UK establishment, then the related premium may not be apportioned. Although the insured party may perceive that they have a non-UK risk, that risk does not attach to a non-UK establishment. No part of the insured’s risk is therefore located abroad for IPT purposes. You should therefore reject any arguments for apportionment on the grounds of exposure where an insured has no establishment abroad.