Hogan Lovells

Key Dates

Brief 3 (2017) issued on 5 October 2017 and subsequently updated on 20 November 2017.

Change in policy to have effect from 1 April 2019, (extended from 1 January 2018).


HMRC has issued a brief (Brief 3 (2017)) to announce a change in the VAT treatment of pension fund management by regulated insurance companies. Up to now, HMRC policy has allowed all pension fund management services provided by regulated insurance companies to be exempt from VAT.

The Brief contains a reminder that, following the EU case of ATP Pension Services, defined contribution pension funds which have all the characteristics of a special investment fund (SIF) will fall within the EU VAT exemption for fund management. HMRC accepts that services of managing and administering these SIF funds are, and always have been, exempt from VAT.

HMRC points out that the SIF exemption is restricted to defined contribution funds and does not extend to defined benefit arrangements.

The Brief announces a change in UK policy so that, from 1 April 2019, insurers will no longer be allowed to treat their supplies of pension fund management services to non-SIF funds as VAT exempt insurance.  (An earlier version of Brief 3 (2017), issued in October 2017, announced that the change in policy would have effect from 1 January 2018 but this has been extended to 1 April 2019.)

Date Accessed: 03/12/2021