VATINS6110 - Supplies of insurance and related services outside the UK: Who receives supplies of insurance and related services? : Recipient of supplies of insurance
The recipient of supplies of insurance is the insured party/policyholder. Where there is more than one party insured under a contract, the place of supply should be determined by reference to the principal insured. Where there is no one principal insured and insured parties are located both inside and outside the UK, the insurance should be treated asbeing received where the majority of insured parties belong or, where applicable, where the party belongs that has been most directly involved in entering into the contract and/or stands to benefit the most from it.
It is important to remember that there can only be one recipient of a supply for VAT purposes and there is no basis for apportionment of input tax recovery where, for example, insured parties are based both inside and outside the UK.