- WTGIL Limited (Ingenie) v HMRC case involved VAT treatment of telematics insurance devices
- ISL, part of Ingenie, specialized in telematics car insurance for young drivers
- Ingenie claimed a £2.08M VAT refund for device costs, arguing devices were separate taxable supplies
- HMRC rejected the claim, viewing devices as part of exempt insurance services
- Ingenie argued device provision was a separate taxable supply, either through non-monetary consideration or commission
- HMRC argued there was no separate contract for device supply, and all services were part of exempt insurance intermediary service
- The Court of Appeal ruled in HMRC’s favor, stating device provision was integral to insurance service
- The decision impacts businesses providing goods as part of exempt services, emphasizing the importance of considering overall commercial reality
- Key takeaway is that goods essential to delivering an exempt service may form part of that exempt supply rather than qualifying as separate taxable supplies
Source: deeksvat.co.uk
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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