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HMRC internal manual

Lloyd's Manual

Reinsurance to close (RITC) and technical provisions: section 107 FA2000: particular difficulties

Particular difficulties may emerge in applying the GI reserves tax Regulations to particular situations such as merging or demerging syndicates or changes in participation around the 4% threshold.

Regulation 9 of SI2001/1957 says that any apportionments that are necessary to perform calculations under the rules shall, subject to express provisions, be just and reasonable. HMRC will not object to practical solutions with this rule in mind, provided these give rise to broadly the same result as would arise on a strict basis and the solution is applied consistently.