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Indirect Tax Case Alerter

 
The tax litigation team from PricewaterhouseCoopers Legal LLP continues its series of alerts for indirect tax case law developments which may arise over coming weeks together with the relevant legislation and history and its analysis of the implications of the case
WHA Ltd and Viscount Reinsurance Co Ltd v HMRC [2004] STC 1081
The issues
 
An insurance company NIG issued motor breakdown insurance (MBI) policies to car buyers. The whole of NIG's risk under the policies was reinsured with a company called Crystal Reinsurance Co Ltd (Crystal) which was incorporated and trading in Gibraltar. 85% of the risk of these MBI policies was retroceded to Viscount Reinsurance Co...

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