Opinion of Advocate General Pikamäe delivered on 14 May 2020.#United Biscuits (Pension Trustees) Limited and United Biscuits Pension Investments Limited v Commissioners for Her Majesty's Revenue and Customs.#Request for a preliminary ruling from the Court of Appeal.#Reference for a preliminary ruling – Value added tax (VAT) – Directive 2006/112/EC – Article 135(1)(a) – Exemption of insurance transactions – Supply of pension fund management services to trustees by investment fund managers – Exclusion of any risk indemnity – Occupational pension scheme – National tax practice – Exercise of an insurance activity – Authorised entities – Entities not holding such authorisation – Concept of ‘insurance transactions’.#Case C-235/19.