The Lloyd’s Underwriters (Conversion to Limited Liability Underwriting) (Tax) Regulations 2006
Under the rules of Lloyd's, an individual member of Lloyd’s may transfer his underwriting business to a company or a Scottish limited partnership (known as “conversion” to limited liability underwriting). Schedule 20A to the Finance Act 1993 allows members so converting to carry forward income tax losses and claim CGT rollover relief on the disposal of certain business assets. A Scottish limited partnership which takes over an individual’s underwriting business on such a conversion is defined in Schedule 20A to the Finance Act 1993 as a “successor partnership.”