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HMRC internal manual

Lloyd's Manual

Capital gains: Names: syndicate capacity: MAPAs: introduction

MAPAs are discussed at LLM1110 and LLM1150.

Establishing the true legal nature of syndicate capacity and the tax consequences thatfollow from transfers of it has presented problems – see LLM4210.

For capacity held via MAPAs, there is additional difficulty in tracking disposals andacquisitions for each MAPA member for each syndicate in which the MAPA is involved. Inrecognition of these two factors Lloyd’s and the Revenue agreed a streamlinedapproach for disposals up to and including 1998-99 (see LLM8120).

Finance Act 1999 introduced legislation to deal with the problems outlined above which, tosome extent, formalised the agreed arrangements. See LLM8150onwards for the position for 1999-2000 and subsequently.