Was the appellant making exempt supplies of insurance or a standard rated supply of services?

Summary

This appeal concerned the VAT liability of supplies of services made by the appellant in connection with the provision of self-invested pension schemes (SIPP) and, in particular whether those supplies were exempt from VAT as the provision of “insurance or reinsurance”.  

Background
Since 2006 the appellant had been the provider, operator and administrators of a SIPP known as the Intelligent Money SIPP (IM SIPP). Until 2014 the appellant understood that the services it provided to members of the SIPP were subject to VAT. However, following a review of the company’s VAT position the appellant formed the view that it had incorrectly accounted for VAT on those supplies and submitted three claims to HMRC which were rejected. 

It was noted that the defining characteristic of a