UK Upper Tier Tribunal: Criteria for VAT supply for consideration clarified in insurance policy case

• UK Upper Tier Tribunal decides that for there to be a supply for a consideration for VAT purposes, five criteria must be satisfied
• Supply and fitting of “black box” device as a condition of insurance policy was not considered a supply for consideration
• WTGIL Limited’s VAT refund on costs for fitting black boxes was rejected by HMRC
• UT decided that there was a supply of services to policyholders, but no consideration was present
• ISL’s argument of deemed taxable supply failed due to absence of ability to deduct input VAT
• UT reminds of the tests to satisfy for there to be a supply for consideration
• Black box fitting services were considered separate from insurance intermediary services by UT, despite HMRC’s argument

Source: dlapiper.com

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.

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