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HMRC internal manual

International Manual

HM Revenue & Customs
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Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: Lloyd’s members' agents

Where the non-resident is a member of Lloyd’s (as defined at FA94/S230) and the transaction is carried out in the course of the non-resident’s underwriting business, a UK agent acting on behalf of the non-resident in relation to the transaction is regarded as an independent agent acting in the ordinary course of his business if they act as member’s agent or as managing agent of the syndicate in question. The UK agent cannot therefore be treated as the ‘UK representative’ of the non-resident Lloyd’s member (see Who can be the non-resident’s UK representative? at INTM268020). The underwriting profits will however continue to be taxable in full in the same way as for resident members.