The nature of syndicate capacity and how it may be acquired and
disposed of is discussed at
LLM1120 onwards.
For individual members a disposal of syndicate capacity is
the disposal of a chargeable asset within the capital gains tax
rules. This means that sales proceeds are not trading receipts and
neither are the purchase price or associated costs allowable as
deductions from trading profits.
These are described at
LLM1130. Neither pre-emption nor
de-emption are chargeable occasions for CGT purposes.
However, if the pre-emption rights are sold at auction, then
this is a sale of a separate right, and is chargeable. There is no
part disposal of syndicate capacity.
Syndicate capacity can be disposed of by being sold, exchanged
or transferred.
LLM8020 deals with acquisition costs and
disposal proceeds.
LLM8030 deals with incidental costs and
initial fees on joining Lloyd's.
LLM8040 deals with acquisitions of
additional capacity in the same syndicate.
LLM8050 deals with indexation and taper
relief.
LLM8060 has an example of a
straightforward computation.
LLM8070 deals with mergers between
syndicates.
LLM8080 explains reversion to the
managing agent.
LLM8090 explains transfer to a successor
vehicle as part of a conversion scheme.
LLM8100 explains the treatment of
syndicate capacity that becomes valueless, for example, where there
is no successor syndicate in which to participate.
LLM8110 onwards explains the CGT
treatment of a transfer of capacity as part of a subscription to a
MAPA operator, and of disposals of MAPA holdings.
