LLM5020 - Names: taxation in earlier years

Over the years, the tax year into which certain elements fall has changed, as has the pre- ITTOIA Case and Schedule of charge. For years of assessment up to 1993-94, syndicate investment income, syndicate capital appreciation and investment income on funds at Lloyd’s were assessed separately, with syndicate chargeable gains or losses assessed to CGT. Lloyd’s profits were taxed on the profits arising in the year.

1994-95 to 1996-97 were exceptional years because they covered the transition from an arising basis to a declaration year basis for the taxation of syndicate results. No syndicate results fell to be taxed in these years, and the taxable profits for each of these years was the aggregate of non-syndicate income and expenditure received or paid in the calendar year ending in the tax year.