LLM3110 - Reinsurance to Close (RITC) and section 107 FA2000: particular difficulties and how to approach them

Particular difficulties may emerge in applying the Regulations to particular situations such as merging or demerging syndicates or changes in participation around the 4% threshold.

Regulation 9 of SI2001/1957 says that any apportionments that are necessary to perform calculations under the rules shall, subject to express provisions, be just and reasonable. HM Revenue & Customs will not object to practical solutions with this rule in mind, provided these give rise to broadly the same result as would arise on a strict basis and provided the solution is applied consistently.