MAPAs are discussed at LLM1110 and LLM1150.
Establishing the true legal nature of syndicate capacity and the tax consequences that follow from transfers of it has presented problems – see LLM4210.
For capacity held via MAPAs, there is additional difficulty in tracking disposals and acquisitions for each MAPA member for each syndicate in which the MAPA is involved. In recognition of these two factors Lloyd’s and the Revenue agreed a streamlined approach for disposals up to and including 1998-99 (see LLM8120).
Finance Act 1999 introduced legislation to deal with the problems outlined above which, to some extent, formalised the agreed arrangements. See LLM8150 onwards for the position for 1999-2000 and subsequently.