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HMRC internal manual

Corporate Intangibles Research and Development Manual

Intangible assets within CTA09/PART8: FA02 rule exceptions: assets already within income regime: syndicate capacity at Lloyd’s



Syndicate capacity on the Lloyd’s insurance market falls within the definition of an intangible fixed asset within Part 8 (see CIRD11100 onwards). See Lloyd’s Manual at LLM1120 for more about syndicate capacity. For periods prior to those to which Part 8 applies (see below) syndicate capacity is regarded for corporation tax as a ‘realisation basis’ asset in that:

  • profits or losses on the disposal of such an asset are recognised as revenue matters in computing trading profits, but
  • changes in the carrying value of an asset (for example by way of amortisation) while it is held are not taken into account at that time.


Section 905 provides that Part 8 applies:

  • to assets within the meaning of Chapter 5 of Part 4 of the FA94 (taxation of corporate members of Lloyd’s) even though they fail the general conditions of the FA02 rule (normally because they were held by the company prior to 1 April 2002);
  • for accounting periods ending on or after 1 April 2002 (including that part of the first accounting period to which Part 8 applies which is before 1 April 2002) and subsequent periods.

Sums charged in the accounts for the amortisation of syndicate capacity therefore give rise to deductible debits under Part 8 for these periods, in practice for accounting periods for the 2002 calendar year onwards.

Section 905 (3) - (5) amends the computational rules as they apply to syndicate capacity in existence for earlier periods to ensure that movements in value recognised in the accounts for those earlier periods, but disallowed for tax, are not taken into account under Part 8 until the asset is realised. See CIRD12775.