Supplies of insurance and related services outside the UK: Who receives supplies of insurance and related services? : Recipients of supplies of reinsurance
The recipient of supplies of reinsurance is the principal insurer and not the parties insured under the primary contract. Only where the recipient is outside the EC is there an entitlement to recover related input tax. It is not possible to “look through”the reinsurance transaction to base the liability on the underlying primary insurance.
A UK company provides reinsurance to an insurer based in the EC. It may not reclaim input tax in respect of the supply, even if the parties who received the initial supply of insurance belong outside the EC.
If the EC insurer has an entitlement to input tax recovery because the insurance is directly linked to the export of goods outside the EC, the entitlement to input tax recovery does not extend to the re-insurer.