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Were the supplies received by the appellant within the insurance exemption?

By Andrew Needham, June 2022

The appellant was an insurance intermediary based in the UK which specialised in providing travel insurance for people aged 50 or over.  It received certain supplies from Intervest Limited, a related company in Gibraltar.  HMRC decided that the supplies received by the appellant from Intervest were standard rated and that the reverse charge provisions applied and registered them for VAT with effect from 1 April 2009.  HMRC issued the appellant with a “global” assessment for £7,915,276 for the period from 1 April 2009 to 31 March 2015 and a belated notification penalty for £1,187,290.  

The appeal raised the following issues summarised below:
(1)          whether the First-tier Tribunal (FTT) had the jurisdiction to hear the appeal against the assessment,       as the appellant made a VAT return after it had filed its Notice of Appeal;
(2)       ; &

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