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HMRC internal manual

VAT Insurance

Insurance underwritten at Lloyd’s of London: Lloyd’s members: corporate members other than SLPs

In most cases, a corporate member provides less than 100% of a syndicate’s capacity.

A corporate member will not be registered solely in respect of its Lloyd’s activities.

Where a syndicate has only one member, which in practice only occurs with a corporate member, the syndicate cannot itself be registered. In this circumstance the corporate member must be registered and all syndicate business accounted for under its registration.

Where a syndicate has two or more members, it is the syndicate rather than the members that are responsible for and registered for VAT, as the taxable person for all syndicate transactions. This is because the syndicate is considered to be an unincorporated body of persons, with any changes in its composition being ignored.

Where there is a syndicate registration, a Lloyd’s member, whether corporate or natural, can also have its own registration in relation to non-syndicate activities. Syndicate activities cannot, however, be dealt with through that registration.

Where the corporate member is covered by a group VAT registration, the group registration is used. It will be entitled to recover a proportion of any Lloyd’s related input tax either using the GMR (see VATINS4310) or at a rate agreed locally. If the corporate member participates only on syndicates that write EU business, there will be no right to recover input tax.