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HMRC internal manual

VAT Insurance

Administration services: general

It may be difficult to establish whether administration services fall within legal note (1)(c), that is, “…the provision of assistance in the administration and performance of insurance contracts”.

We would expect these services to be the type of services you would normally expect a broker or agent to carry out as part of the routine administration of a contract of insurance (such as, changes to policy details and cover).

However, our view on this was updated to take account of the decision of the Court of Appeal in Century Life Plc (see VATINS5410) which extended the definition of administration services to include services performed in connection with a one-off regulatory requirement.

The Judge in Century Life considered what constituted ‘insurance related’ services. He found that, to qualify, services had to have a close nexus with the underlying insurance transaction, and general administration services supplied to an insurance company, such as secretarial and computer services, did not qualify.

The judgement in Century Life has been reviewed following enquiries made by the EU Commission in the light of more recent CJEU caselaw - see VATINS5410 for more information.