Corporate members: profits not charged under Case I
Under Lloyd’s rules a corporate member may have no trade other than underwriting, and is unlikely to have assets other than those used in connection with its underwriting at Lloyd’s. It is unlikely that profits will arise to corporate members that are not charged under Case I of Schedule D. One exception might be investment income and gains arising on retained profits of the underwriting business. However, where retained profits are at risk in the underwriting business their taxation treatment will also be governed by FA94/S219 (3)(b).
In the unlikely event that a corporate member does have profits (or losses) that are clearly unconnected with the business of underwriting at Lloyd’s those profits should be dealt with under normal corporation tax rules.