Insurance premium tax (IPT), a tax payable on most insurance policies, is payable depending on where the risk being insured lies. There is some uncertainty as to how to determine the location of risk, particularly in merger and acquisition deals, in which both the seller and buyer seek to insure a common risk. This article discusses the history behind IPT in the Netherlands, the purposes it is meant to serve and how the recent case law can help in determining the location of risk.