LLM3310 - Reinsurance to close (RITC) and technical provisions: taxation following repeal of section 107 FA 2000: the appropriate amount: adaptations of FA07/SCH11

The following adaptations and special provisions are made to the primary legislation within FA07/SCH11 to cater for members of Lloyd바카라 사이트™s syndicates.

  • For the purposes of the possible restriction to the 바카라 사이트˜appropriate amount바카라 사이트™, the term 바카라 사이트˜general insurer바카라 사이트™ is extended to include members of a Lloyd바카라 사이트™s syndicate (FA07/SCH11/PARA3 (1)(c)).
  • The accounts by reference to which the rules are to apply are taken to be the syndicate accounts (FA07/SCH11/PARA3 (4)).
  • The reference to 바카라 사이트˜period of account바카라 사이트™ is to be taken to mean an underwriting year for which profits or losses are declared (FA07/SCH11/PARA3 (5)(b)).
  • The reference to 바카라 사이트˜technical provisions바카라 사이트™ is to be taken to mean, in the case of a closed syndicate the reinsurance to close (or deemed reinsurance to close), and in the case of an open syndicate, the provisions for claims outstanding, unearned premiums and unexpired risks (FA07/SCH11/PARA3 (7)).
  • Regulations may be made by HMRC to reduce the adjustments in relation to particular syndicate members. This is a reserve power, designed to deal with the possibility that members of syndicates may pay reinsurance premiums on their own behalf, the effect of which will be to require the unpaid claims liabilities (net of reinsurance) to be recalculated in these particular cases (FA07/SCH11/PARA3 (11)).
  • Regulations under existing administrative powers in FA93 (for income tax) and FA94 (for corporation tax) may adapt assessment and collection rules to cater for the enforcement provisions in FA07/SCH11/PARA 2 (FA07/SCH11/PARA3 (14)). See LLM3330.

In addition, FA07/SCH11/PARA3 (8) provides definitions for reinsurance to close and 바카라 사이트˜open Lloyd바카라 사이트™s syndicate바카라 사이트™, and FA07/SCH11/PARA3 (9) explains that a syndicate is formed for an 바카라 사이트˜underwriting year바카라 사이트™ which is a calendar year.