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.
