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Wheels Private Hire v HMRC

In Wheels Private Hire v HMRC [2015] UKFTT 363 (21 July 2015) the FTT found that the supply of optional insurance together with that of car hire was not a single composite supply.

Wheels ran a taxi business. Some of the drivers rented its cars for £120 per week and they had the option of adding insurance for an additional £45 per week. The issue was whether the payment for insurance was for a separate and exempt supply (VATA 1994 Sch 9 group 2) or was part of single standard rated supply.

The FTT first observed that the term ‘block policy’ (considered in Card Protection Plan (C-349/96)) was not defined although it was covered in HMRC guidance in Notice 701/36. However its suggested characteristics were a contract between insurer and policy holder who in turn could procure insurance or insurance cover for third parties. A ‘fleet...

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