SCHEDULES
F1SCHEDULE 20AF4F5Lloyd’s underwriters: conversion to underwriting through partnership or company
Sch. 20A heading substituted (19.12.2014) by The Lloyd's Underwriters (Conversion of Partnerships to Underwriting through Successor Companies) (Tax) Regulations 2014 (S.I. 2014/3133), regs. 1, 5(7)
Words in Sch. 20A heading inserted (16.6.2016) by The Lloyds Underwriters (Roll-over Relief on Disposal of Assets of Ancillary Trust Fund) (Tax) Regulations 2016 (S.I. 2016/597), regs. 1(1), 9
Part 2Conversion to underwriting through successor partnerships
Income tax: carry forward of loss relief following conversion
7
1
This paragraph applies if—
a
the member’s total income for a year of assessment includes profits of the successor partnership’s underwriting business, and
b
throughout the period beginning with the time of the syndicate capacity disposal and ending with the end of that year of assessment, the member is beneficially entitled to more than 50% of the profits of that business.
2
F3Section 83 of ITA 2007 (carry-forward of trading losses against subsequent profits) shall have effect, in its application in relation to the losses of the old underwriting business, as if the profits of the successor partnership’s underwriting business to which the member is beneficially entitled for that year were profits on which the member was assessed under F2 Part 2 of the Income Tax (Trading and Other Income) Act 2005 in respect of the old underwriting business for that year.
3
In sub-paragraph (2) above “the old underwriting business” means the member’s underwriting business carried on otherwise than through the successor partnership.
Sch. 20A inserted (22.7.2004) by Finance Act 2004 (c. 12), Sch. 25 para. 3