LLM3000 - Reinsurance to close (RITC), technical provisions and equalisation reserves: introduction
Reinsurance to close and technical provisions
GIM Chapter 6 (see LLM10000) addresses the special tax issues that relate to technical provisions of general insurance companies. Similar issues arise in relation to reinsurance to close (바카라 사이트˜RITC바카라 사이트™) and, for open syndicates, technical provisions for Lloyd바카라 사이트™s syndicate members. GIM6080 explains the background to the introduction of FA00/S107 and the General Insurance Reserves (Tax) Regulations 2001, SI2001/1757. This legislation applied specific and complex tax rules to the taxation of technical provisions of a general insurer, including Lloyd바카라 사이트™s underwriting members. These rules are described at GIM6150 to GIM6340 and the corresponding rules and adaptations for Lloyd바카라 사이트™s members are at LLM3010 to LLM3200 in this Chapter.
LLM3210 explains a special rule that applied to RITC before the introduction of FA00/S107.
GIM6510+ explains the rules for general insurance companies following the repeal of FA00/S107 by FA07/SCH11. The corresponding rules and adaptations for Lloyd바카라 사이트™s syndicates are at LLM3300 to 3330 below.
Equalisation reserves
FA09/S47 empowers the Treasury to make regulations extending existing equalisation relief, given to general insurance companies for the equalisation reserves they are required by the Financial services Authority to establish, so that it may also benefit corporate and partnership members of Lloyd바카라 사이트™s who choose to establish 바카라 사이트˜equivalent Lloyd바카라 사이트™s reserves바카라 사이트™. The effect of these regulations, The Lloyd바카라 사이트™s Underwriters (Equalisation Reserves) (Tax) Regulations 2009, SI2009/2039, is described at LLM3400+. Equalisation reserves recognise the volatile and fluctuating results associated with certain general insurance business classes.
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LLM3010Section 107 FA2000: application to Lloyd's members: general
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LLM3020Section 107 FA2000: application to Lloyd's members: the 4% rule
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LLM3030Section 107 FA2000: application to Lloyd's members: periods affected
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LLM3040Section 107 FA2000: adaptations for Lloyd's members: meaning of technical provisions
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LLM3050Section 107 FA2000: adaptations for Lloyd's members: changes in a member바카라 사이트™s share of a syndicate바카라 사이트™s business
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LLM3060Section 107 FA2000: adaptations for Lloyd's: changes in a member바카라 사이트™s share of a syndicate바카라 사이트™s business: examples
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LLM3070Section 107 FA2000: adaptations for Lloyd's members: the declarations basis and the 'one-year later' rule
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LLM3080Section 107 FA2000: adaptations for Lloyd's members (page 1 of 3): regulation 7(1) to (3) of the GI reserves tax Regulations
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LLM3090Section 107 FA2000: adaptations for Lloyd's members (page 2 of 3): regulation 7(4) and (5) of the GI reserves tax regulations
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LLM3100Section 107 FA2000: adaptations for Lloyd's members (page 3 of 3): regulation 7(6) to (11) of the GI reserves tax regulations
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LLM3110Section 107 FA2000: particular difficulties
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LLM3120Section 107 FA2000: further help available: the 'Lloyd's Calculator'
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LLM3130Section 107 FA2000: example: member increases their share of a syndicate바카라 사이트™s business (page 1 of 4)
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LLM3140Section 107 FA2000: example: member increases their share of a syndicate바카라 사이트™s business (page 2 of 4)
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LLM3150Section 107 FA2000: example member increases their share of a syndicate바카라 사이트™s business (page 3 of 4)
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LLM3160Section 107 FA2000: example member increases their share of a syndicate바카라 사이트™s business (page 4 of 4)
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LLM3170Section 107 FA2000: example: member reduces their share of a syndicate바카라 사이트™s business (page 1 of 4)
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LLM3180Section 107 FA2000: example: member reduces their share of a syndicate바카라 사이트™s business (page 2 of 4)
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LLM3190Section 107 FA2000: example: member reduces their share of a syndicate바카라 사이트™s business (page 3 of 4)
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LLM3200Section 107 FA2000: example: member reduces their share of a syndicate바카라 사이트™s business (page 4 of 4)
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LLM3210Taxation prior to section 107 FA 2000
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LLM3300Taxation following repeal of section 107 FA2000: the appropriate amount: adaptations for Lloyd바카라 사이트™s members
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LLM3310Taxation following repeal of section 107 FA 2000: the appropriate amount: adaptations of FA07/SCH11
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LLM3320Taxation following repeal of section 107 FA 2000: appropriate amount Regulations SI2009/1926: application to members of Lloyd바카라 사이트™s syndicates
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LLM3330Taxation following repeal of section 107 FA 2000: the appropriate amount: application to Lloyd바카라 사이트™s syndicates: amendment of the administrative regulations for enforcement purposes
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LLM3400Equalisation reserves for corporate and partnership members: background
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LLM3410Equalisation reserves for corporate and partnership members: scope of relief
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LLM3420Equalisation reserves for corporate and partnership members: equivalent Lloyd바카라 사이트™s reserve
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LLM3430Equalisation reserves for corporate and partnership members: application of the section 444BA ICTA rules
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LLM3440Equalisation reserves for corporate and partnership members: election not to take a tax deduction
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LLM3450Equalisation reserves for corporate and partnership members: cessations
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LLM3460Equalisation reserves for corporate and partnership members: anti-avoidance
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LLM3470Equalisation reserves for corporate and partnership members: repeal