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HMRC internal manual

VAT Insurance

Insurance underwritten at Lloyd’s of London: Lloyd’s members: individual members and Scottish limited partnerships (SLPs)

Because, the syndicate is responsible for accounting for VAT, we will not register an individual member LLP or an SLP, solely in respect of their Lloyd’s activities. Where an individual member is registered as a sole proprietor in respect of other, non-Lloyd’s activities, input tax relating to their Lloyds activities may be recoverable through that registration at a rate agreed with us.

Under the LVA an individual Name can normally use the Global Market Rate (‘GMR’) to calculate the recoverable amount. The GMR, which is calculated by Lloyd’s, is designed to reflect the overall mix of business underwritten by the whole of the Lloyd’s market but does not produce a fair and reasonable recovery rate in all cases. Members who participate only on syndicates writing nothing but EU business will be unable to recover any underwriting related input tax as they have only written insurance in respect of which there is no right to recover input tax.