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HMRC internal manual

VAT Partial Exemption Guidance

Guidance for specific trade sectors: Lloyd's VAT arrangements: natural members - Partial Exemption method

Input tax arising from underwriting activities incurred by natural members who are registered for VAT as sole proprietors by virtue of business activities other than underwriting at Lloyd’s may be recovered subject to the normal rules. The Global Market Rate will normally be used to calculate the recoverable amount. The exception to this will be any members who participate solely on syndicates that write only EU business. These members 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.

Natural members who are VAT registered other than as sole proprietors are not entitled to recover input tax arising from their underwriting activities by virtue of that registration.