Skip to content
Solved
SearchBrowse
Sign in

Contents

Official guidance
Lloyd's Manual

LLM3000 · Reinsurance to close (RITC), technical provisions and equalisation reserves: introduction

  • LLM3010 · Reinsurance to close (RITC) and technical provisions: section 107 FA2000: application to Lloyd’s members: general
  • LLM3020 · Reinsurance to close (RITC) and technical provisions: section 107 FA2000: application to Lloyd's members: the 4% rule
  • LLM3030 · Reinsurance to close (RITC) and technical provisions: section 107 FA2000: application to Lloyd's members: periods affected
  • LLM3040 · Reinsurance to close (RITC) and technical provisions: section 107 FA2000: adaptations for Lloyd's members: meaning of technical provisions
  • LLM3050 · Reinsurance to close (RITC) and technical provisions: section 107 FA2000: adaptations for Lloyd's members: changes in a member’s share of the syndicate’s business
  • LLM3060 · Reinsurance to close (RITC) and technical provisions: section 107 FA2000: adaptations for Lloyd's members: changes in a member’s share of the syndicate’s business: examples
  • LLM3070 · Reinsurance to close (RITC) and technical provisions: section 107 FA2000: adaptations for Lloyd's members: the declarations basis and the 'one-year later'’ rule
  • LLM3080 · Reinsurance to close (RITC) and technical provisions: section 107 FA2000: adaptations for Lloyd's members (page 1 of 3): regulation 7(1) to (3) of the GI reserves tax Regulations
  • LLM3090 · Reinsurance to close (RITC) and technical provisions: section 107 FA2000: adaptations for Lloyd's members (page 2 of 3): regulation 7(4) and (5) of the GI reserves tax Regulations
  • LLM3100 · Reinsurance to close (RITC) and technical provisions: section 107 FA2000: adaptations for Lloyd's members (page 3 of 3): regulation 7(6) to (11) of the GI reserves tax Regulations
  • LLM3110 · Reinsurance to close (RITC) and technical provisions: section 107 FA2000: particular difficulties
  • LLM3120 · Reinsurance to close (RITC) and technical provisions: section 107 FA2000: further help available: the ‘Lloyd's Calculator’
  • LLM3130 · Reinsurance to close (RITC) and technical provisions: section 107 FA2000: example: member increases their share of the syndicate’s business (page 1 of 4)
  • LLM3140 · Reinsurance to close (RITC) and technical provisions: section 107 FA2000: example: member increases their share of the syndicate’s business (page 2 of 4)
  • LLM3150 · Reinsurance to close (RITC) and technical provisions: section 107 FA2000: example: member increases their share of the syndicate’s business (page 3 of 4)
  • LLM3160 · Reinsurance to close (RITC) and technical provisions: section 107 FA2000: example: member increases their share of the syndicate’s business (page 4 of 4)
  • LLM3170 · Reinsurance to close (RITC) and technical provisions: section 107 FA2000: example: member reduces their share of the syndicate’s business (page 1 of 4)
  • LLM3180 · Reinsurance to close (RITC) and technical provisions: section 107 FA2000: example: member reduces their share of the syndicate’s business (page 2 of 4)
  • LLM3190 · Reinsurance to close (RITC) and technical provisions: section 107 FA2000: example: member reduces their share of the syndicate’s business (page 3 of 4)
  • LLM3200 · Reinsurance to close (RITC) and technical provisions: section 107 FA2000: example: member reduces their share of the syndicate’s business (page 4 of 4)
  • LLM3210 · Reinsurance to close (RITC) and technical provisions: taxation before and after section 107 FA 2000
  • LLM3300 · Reinsurance to close (RITC) and technical provisions: taxation following repeal of section 107 FA2000: the appropriate amount: adaptations for Lloyd’s members
  • LLM3310 · Reinsurance to close (RITC) and technical provisions: taxation following repeal of section 107 FA 2000: the appropriate amount: adaptations of FA07/SCH11
  • LLM3320 · Reinsurance to close (RITC) and technical provisions: taxation following repeal of section 107 FA 2000: appropriate amount Regulations SI2009/1926: application to members of Lloyd’s syndicates
  • LLM3330 · Reinsurance to close (RITC) and technical provisions: taxation following repeal of section 107 FA 2000: the appropriate amount: application to Lloyd’s syndicates: amendment of the administrative regulations for enforcement purposes
  • LLM3400 · Equalisation reserves for corporate and partnership members: background
  • LLM3410 · Equalisation reserves for corporate and partnership members: scope of relief
  • LLM3420 · Equalisation reserves for corporate and partnership members: equivalent Lloyd’s reserve
  • LLM3430 · Equalisation reserves for corporate and partnership members: application of the section 444BA ICTA rules
  • LLM3440 · Equalisation reserves for corporate and partnership members: election not to take a tax deduction
  • LLM3450 · Equalisation reserves for corporate and partnership members: cessations
  • LLM3460 · Equalisation reserves for corporate and partnership members: anti-avoidance
  • LLM3470 · Equalisation reserves for corporate and partnership members: repeal
  1. Reinsurance to close (RITC), technical provisions and equalisation reserves: introduction
  2. Reinsurance to close (RITC) and technical provisions: section 107 FA2000: example: member reduces their share of the syndicate’s business (page 1 of 4)

LLM3170 | Reinsurance to close (RITC) and technical provisions: section 107 FA2000: example: member reduces their share of the syndicate’s business (page 1 of 4)

From HM Revenue & Customs · Lloyd's Manual

Where the member’s share of business increases (say from 20% to 25%) it seems straightforward that the original provisions were only 20% of the syndicate’s total. But where the member’s share of business reduces (say from 25% to 20%) the original provision is still only 20% of the syndicate’s business. The other 5% is payment of claims of the earlier year, and not a provision.

This brings out how the ’lesser of’ rule in regulation 7(1) described at LLM3080 operated. As outlined at LLM3050, where a member reduces their share of the syndicate’s business, part of the RITC premium paid will be paid to a third party. This part therefore represents not a provision, but the cost of settling liabilities. It was therefore treated as such for the purposes of the calculation required by FA00/S107.

Example

Year of accountLiabilities forRITC paidClaims paid
19971997£50M-
Z has 40% share£20M-
19981997£40M£20M
1998£60M£60M
total£100M£80M
Z has 25% share£25M£20M
19991997£30M£10M
1998£60M£20M
1999£60M£80M
total£150M£110M
Z has 20% share£30M£22M

The RITC premium for 1997 would actually be paid at 31 December 1999 and claims against it would be paid in year ended 31 December 2000.

The figures for the FA00/S107 calculations are at LLM3180 to LLM3200.

PreviousNext
PrivacyTerms