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HMRC internal manual

Lloyd's Manual

Conversion: Schedule 20A FA93: Nameco conversions: trading losses

FA93/SCH20A/PARA2 applies where the converting Name receives income from the Nameco, and continues to own the majority of shares in, and to control, the company throughout a tax year. It allows trading losses from before the conversion to be set off against subsequent income derived from the company, under the “carry forward provision”, which means ICTA88/S385 and ITA07/S83. On a claim, therefore, the income derived from the company is treated as if it were underwriting profits. As with trade transfer relief, ICTA88/S386 and ITA07/S86, such income can be remuneration, dividends or other income.