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HMRC internal manual

Lloyd's Manual

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HM Revenue & Customs
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Introduction to Lloyd's: basic concepts and terms: managing agents and premium trust funds: aligned member syndicates

With effect from 1 July 2007, aligned corporate member syndicates may hold “membercapital” in the syndicate premium trust fund. This capital would formerly have beenheld by the member in its Personal Reserve Fund and forms part of Funds at Lloyd’s(see LLM1200).

This Lloyd’s practice change was designed to recognise the commercial alignmentbetween member and managing agent, simplifying the trustee arrangements, reducing the needfor transfers between funds and facilitating trust asset management. Special tax treatmentis needed to apply the correct basis of assessment, distinguishing between profits arisingon member capital and that arising on ordinary syndicate capital – see LLM4105.