This month’s review by Gary Barnett (Simmons & Simmons) covers an important advocate general’s opinion.
Fees paid to SIPP administrator
In Intelligent Money Ltd v HMRC [2022] UKFTT 148 the First-tier Tribunal (FTT) held that fees paid to the administrator of a SIPP (self-invested personal pension) are not consideration for an exempt supply of insurance. Although the FTT concluded that a SIPP amounted to a form of insurance it was clear from the case law of the CJEU that the VAT exemption for insurance was narrower and required the insurer to take on risk in return for payment of the premiums. That was not the case with the SIPP which was in essence an investment product.
Intelligent Money Ltd (IM) is the provider operator and administrator of a SIPP known as the Intelligent Money SIPP. IM sought recovery of overpaid VAT from HMRC...
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This month’s review by Gary Barnett (Simmons & Simmons) covers an important advocate general’s opinion.
Fees paid to SIPP administrator
In Intelligent Money Ltd v HMRC [2022] UKFTT 148 the First-tier Tribunal (FTT) held that fees paid to the administrator of a SIPP (self-invested personal pension) are not consideration for an exempt supply of insurance. Although the FTT concluded that a SIPP amounted to a form of insurance it was clear from the case law of the CJEU that the VAT exemption for insurance was narrower and required the insurer to take on risk in return for payment of the premiums. That was not the case with the SIPP which was in essence an investment product.
Intelligent Money Ltd (IM) is the provider operator and administrator of a SIPP known as the Intelligent Money SIPP. IM sought recovery of overpaid VAT from HMRC...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
