Under Lloyd’s rules a corporate member may have no
trade other than underwriting, and is unlikely to have assets other
than those used in connection with its underwriting at
Lloyd’s. It is unlikely that profits will arise to corporate
members that are not charged under Case I of Schedule D. One
exception might be investment income and gains arising on retained
profits of the underwriting business. However, where retained
profits are at risk in the underwriting business their taxation
treatment will also be governed by FA94/S219 (3)(b).
In the unlikely event that a corporate member does have
profits (or losses) that are clearly unconnected with the business
of underwriting at Lloyd’s those profits should be dealt with
under normal corporation tax rules.
