Warranty and Indemnity insurance and tax

W&I insurance and tax. The ECJ has confirmed (19 January decision) in A Ltd v Veronsaajien that for cross-border transactions, insurance premium tax is payable in the country where the policyholder is based i.e. where the contractual risk is, rather than where the target company is based, writes Partner Stephen Reilly. Rates vary across Europe from as low as 2% up to 30% in some instances. IPT is 20% in the UK.