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Tartaruga: locating the risk for IPT purposes

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Insurance premium tax has become an increasingly important tax for the UK exchequer. In Tartaruga, the First-tier Tribunal has considered the extent to which insurance contracts related to risks situated outside the UK and were therefore outside the scope of UK IPT. The decision provides important insight into how an establishment is identified under the regime and, in particular, the distinction between temporary or permanent establishments.

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