The Lloyd’s Underwriters (Conversion of Partnerships to Underwriting through Successor Companies) (Tax) Regulations 2014
Schedule 20A of the Finance Act 1993 (“FA 1993”) makes provision for certain reliefs to be available to individual members of Lloyd’s who convert to limited liability underwriting. As a consequence of changes to the rules of Lloyd’s which have made it more likely that Lloyd’s members that are limited liability partnerships or limited partnerships formed under the law of Scotland will want to convert to underwriting through successor companies, the Commissioners for Her Majesty’s Revenue and Customs consider it expedient to make amendments to FA 1993. These Regulations amend FA 1993 to include provision under Schedule 20A for relief from capital gains tax to be available in specified circumstances to individuals who are members (in the case of limited liability partnerships) or partners (in the case of Scottish limited partnerships) of partnerships that convert to underwriting through successor companies.