The value of an individual Name’s Lloyd’s interests normally qualifies for 100% relief under IHTA84/S105 (1)(a).
An interest in a trading partnership, as with a corporate vehicle, should attract 100% relief as should Funds at Lloyd’s (FAL) assets utilised by an SLP or LLP through interavailability.
‘Corporate member’ here refers to incorporated
companies that are members of Lloyd’s, including
‘Namecos’. In broad terms, companies are not subject to
IHT. However, shareholdings in corporate vehicles should attract
business property relief (BPR) of 100% where unquoted or 50% for
shares or securities giving control of a quoted company.
A shareholding in a Nameco will qualify for BPR at 100%
providing the two-year ownership condition of IHTA84/S106 is
satisfied.
As a general rule, FAL assets do not qualify for BPR during
the first two years of a new business. However, special rules
(IHTA84/S107) apply for replacement property and, provided a Name
transfers the whole of his bespoke business to a new corporate
business, the new business will be treated as replacement property.
In the situation where a Name was in the process of
transferring their entire personal business into a Nameco at the
date of death, the shares allotted in return for the tendering of
eligible capacity will be treated as replacement property within
the meaning of IHTA84/S107 and BPR at 100% will be available.
