Summary
This was an appeal by the appellant against a decision of the First-tier Tribunal (the FTT) dismissing a claim by the appellant for repayment of VAT overpaid.â¯The appeal concerns the liability to VAT of services provided by the appellant in connection with the provision, operation and administration of self-invested personal pension schemes (SIPPs), and, in particular whether those supplies fell within the exemption from VAT for “insurance and reinsurance transactions” contained in item 1 Group 2 Schedule 9 to the VAT Act 1994.â¯
Background
The First-tier Tribunal (FTT) had considered the UK case law concerning the meaning of ‘insurance’ in various contexts. In the course of that review, the FTT identified the key features of an insurance contract as set out by Channell J inâ¯Prudential as being:
(i) a contract whereby, for some consideration, the
