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HMRC internal manual

Lloyd's Manual

HM Revenue & Customs
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Reinsurance to close (RITC) and technical provisions: section 107 FA2000: application to Lloyd's members: the 4% rule

Regulation 7(1) and 7(8) of the GI reserves tax Regulations made clear that the rules only apply to Lloyd’s members that have a 4% or greater share of both the syndicate that pays and the syndicate that receives the RITC (LLM3080).

For corporate members, the syndicate entitlements of connected companies had to be aggregated in determining whether the member has a 4% share of a syndicate (LLM3100).

In practice this meant that the rules applied to very few private capital investors (individual members, partnership and Namecos). Larger corporate members usually came within the rules.