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HMRC internal manual

Lloyd's Manual

HM Revenue & Customs
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Reinsurance to close (RITC) and technical provisions: taxation following repeal of section 107 FA 2000: the appropriate amount: application to Lloyd’s syndicates: amendment of the administrative regulations for enforcement purposes

There are two separate issues which affect the enforcement powers under FA07/SCH11/PARA2 as it affects reinsurance to close and provisions for Lloyd’s syndicates and their members. The first is the addition by SI2009/2889 of a new regulation 5A to the Lloyd’s Underwriters (Tax) Regulations 2005, SI2005/3338, which applies the provisions of FA07/SCH11/PARA2 to syndicate managing agents. The effect is to enable HMRC to require syndicate managing agents to provide a report relating to the amount of provisions (or reinsurance to close) stated in the syndicate accounts. SI2009/2889 applies to FA07/SCH11/PARA2 as amended following the HMRC Powers Review by paragraph 53 of the Schedule to SI2009/2035.

The second issue is the appearance of Lloyd’s managing agents in the Table added by FA09/SCH48/PARA14 at FA08/SCH36/PARA61A. This makes syndicate managing agents ‘involved third parties’ in the terms of FA08/SCH36/PARA34A added by FA09/SCH48/PARA11. It means that third party notices can be served on the managing agent in relation to individual syndicate members’ RITC and provisions without Tribunal approval. This provision operates from an appointed day, expected to be 1 April 2010.