In Royal Bank of Scotland Group plc v HMRC (No 8) (Ch D – 17 January) a UK insurance company (P) entered into a series of agreements in January 2002 under which it sold its general insurance business to a Swiss insurance company (W). In February 2002 W novated its rights under the agreements to an associated Bermuda company. In 2003 the Bermuda company novated the rights to a company which was a subsidiary of a Scottish bank (R). R paid commission to P primarily as a result of the renewal of general insurance policies which had been in place before P sold its general insurance business to W. Customs issued a ruling that VAT was chargeable on the commission. R appealed contending that the commission related to services of an insurance intermediary which qualified for exemption. The VAT Tribunal rejected this contention and...
