LLM3000 - Reinsurance to Close (RITC) and section 107 FA2000


FA00/S107 and the General Insurance Reserves (Tax) Regulations (SI2001/1757) apply specific tax rules to the taxation of ‘technical provisions’ of a general insurer. ‘General insurer’ includes a Lloyd’s underwriter. Details of the main rules and how they operate can be found in GIM6000+ in the General Insurance Manual (see LLM10000).

For Lloyd's underwriters, the term ‘technical provisions’ means the Reinsurance to Close (RITC) premium ( LLM2060) paid (or treated as paid under Lloyd’s rules), and the provisions for unpaid liabilities of an open syndicate.

This section of the Lloyd’s Manual explains how the rules in FA00/S107 are adapted for Lloyd’s members.

For periods prior to the introduction of FA00/S107, there were special rules on the taxation of the RITC premium ( LLM3210).

LLM3010How the rules are applied to Lloyd's members
LLM3020Which Lloyd's members must apply the rules (“the 4% rule”)
LLM3030When the rules apply to Lloyd's members
LLM3040Why the rules need to be adapted for Lloyd's: what are the technical provisions?
LLM3050Why the rules need to be adapted for Lloyd's: changes in a member’s share of a syndicate’s business
LLM3060Why the rules need to be adapted for Lloyd's: changes in a member’s share of a syndicate’s business: examples
LLM3070Why the rules need to be adapted for Lloyd's: the declarations basis and the “one-year later” rule
LLM3080How the rules are adapted for Lloyd's (page 1 of 3): regulation 7(1) to (3)
LLM3090How the rules are adapted for Lloyd's (page 2 of 3): regulation 7(4) to (5)
LLM3100How the rules are adapted for Lloyd's (page 3 of 3): regulation 7(6) to (11)
LLM3110Particular difficulties and how to approach them
LLM3120Further help available: the Lloyd's Calculator
LLM3130Example of a calculation where a member increases their share of a syndicate’s business (page 1 of 4)
LLM3140Example of a calculation where a member increases their share of a syndicate’s business (page 2 of 4)
LLM3150Example of a calculation where a member increases their share of a syndicate’s business (page 3 of 4)
LLM3160Example of a calculation where a member increases their share of a syndicate’s business (page 4 of 4)
LLM3170Example of a calculation where a member reduces their share of a syndicate’s business (page 1 of 4)
LLM3180Example of a calculation where a member reduces their share of a syndicate’s business (page 2 of 4)
LLM3190Example of a calculation where a member reduces their share of a syndicate’s business (page 3 of 4)
LLM3200Example of a calculation where a member reduces their share of a syndicate’s business (page 4 of 4)
LLM3210Reinsurance To Close (RITC): taxation prior to section 107 FA 2000