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HMRC internal manual

Lloyd's Manual

From
HM Revenue & Customs
Updated
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Capital gains: Names: syndicate capacity: acquisition and disposal: incidental costs

Auction fees

Names pay fees to take part in capacity auctions, either as buyer or seller. Purchasersalso pay a fee based on the cost of capacity purchased. Both these types of fees areallowable as incidental costs of acquisition or disposal that can be deducted from thegain.

Initial subscriptions

On joining Lloyd’s, an Entrance or Admission Fee is paid. When a Name resigns andfinally disposes of all his syndicate capacity, this fee is regarded as an incidental costof disposal of the capacity and may be deducted from the chargeable gain. The fee is alsoallowable as a capital loss if the Name simply allows capacity to lapse, rather thanselling it. Like other incidental costs of disposal, the amount of the fee is not includedin the relevant allowable expenditure for indexation purposes.