RCB/3/17 VAT—treatment of pension fund management services

RCB/3/17 VAT—treatment of pension fund management services

Revenue & Customs Brief, Issue 3. Updated 20 November 2017

Purpose of this brief

This brief announces a change in HM Revenue and Customs (HMRC) policy about the VAT treatment of pension fund management services provided by regulated insurance companies.

Readership

This Revenue and Customs brief is primarily aimed at—

1.  

   —     pension fund managers and administrators

2.  

   —     insurers and other pension providers

3.  

   —     pension scheme trustees

4.  

   —     tax advisers.

Background

HMRC policy has allowed all pension fund management services provided by regulated insurance companies to be exempt from VAT. This treatment arises from the UK's original application of the insurance exemption to all of an insurer's regulated insurance activities, including the management of pension funds.

Following the Court of Justice of the European Union (CJEU) judgement in Card Protection Plan (CPP), UK law was amended from 1 January 2005 to remove any link