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HMRC internal manual

VAT Insurance

From
HM Revenue & Customs
Updated
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Supplies of insurance and related services outside the UK: multiple places of belonging

This can affect both the provider and the recipient of the insurance service. An insurer may have branches or agencies in a number of locations, and particular supplies must be treated as being made in the location most closely connected with the supply, as per section 9 VAT Act 1994. Similarly, an insured person (such as, a multinational corporation) may have offices worldwide. It will be necessary, where possible, to isolate the location(s) most directly concerned with the particular supply of insurance in order to decide the place of supply and hence the input tax recovery position for the insurer and broker or other intermediary.

Very often, it is impossible to establish which location is most directly concerned with receiving the insurance. The tendency here is to treat the supply as received where the first-named insured (typically the parent company) belongs, or where the group’s insurance affairs are arranged. Where this is the case, you should take care to confirm that the arrangement is not being manipulated for input tax recovery.