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HMRC internal manual

Lloyd's Manual

HM Revenue & Customs
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Conversion: Schedule 20A FA93

The conversion reliefs are contained in a new section 179B of, and a new Schedule 20A to, Finance Act 1993. They therefore form part of the existing legislation in Finance Act 1993 which applies to individual Names.

FA93/SCH20A is in three parts.

  • Part 1 applies to conversion to “successor companies”, which essentially means Namecos.
  • Part 2 applies to conversion to “successor partnerships”, which means SLPs and LLPs.
  • Part 3 contains supplementary provisions.

The conditions in Part 1 which apply to Nameco conversions are different from those in Part 2 which apply to SLP/LLP conversions. In both cases, however, the reliefs apply only to a single Name who converts to a personal Nameco, or to an SLP or LLP in which they are the only underwriting partner. The reliefs are not available to Names who convert via collective conversion schemes, or to several Names who convert to the same Nameco or SLP/LLP. And in both cases there must be continuity of underwriting from the Name to the conversion vehicle.