WTGIL Ltd v HMRC

In WTGIL Ltd v HMRC [2024] UKUT 77 (TCC) (26 March 2024) the UT ruled that VAT was not recoverable in relation to costs incurred by an insurance intermediary that installed telematics devices in cars because the costs were not attributable to a taxable supply made for consideration.

The appellant was the representative member of a VAT group. One of the members of the VAT group Ingenie Services Ltd (ISL) supplied car insurance intermediary services to young drivers on contractual terms whereby ISL incurred VAT-bearing costs in relation to the installation of telematics devices in cars. The devices sometimes known as black boxes capture information about the way cars are driven so that insurers can use the information to adjust the premiums charged. It was common ground that for ISL to be entitled to recover VAT on the costs the costs must be attributable to...