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WTGIL Ltd v HMRC

In WTGIL Ltd v HMRC [2022] UKFTT 131 (TC) (12 April 2022) the FTT held that an insurance intermediary made neither a supply for consideration nor a deemed supply to policyholders in relation to ‘black box’ devices fitted in their cars to analyse their driving. Consequently input tax was not recoverable in respect of the provision and fitting of the devices. 

The taxpayer was the representative member of a VAT group which contained a company previously called Ingenie Services Limited (ISL). ISL was an insurance intermediary which developed marketed and sold ‘telematics’ car insurance (also known as black box insurance). ISL was not an insurer and policies were underwritten by insurers from a panel appointed by it.

As a condition of the insurance policy a telematic device (or black box) had to be installed in a policyholder’s car. This device transmitted various information to ISL allowing ISL...

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