The commentary below considers the exposure of Lloyd's members to tax on chargeable gains arising within the various funds. For an overview of the taxation of chargeable gains generally, see C1.101.
Background
Lloyd's is a market through which independent insurance underwriters join together in syndicates to sell insurance, usually through its brokers, under the umbrella of the Lloyd's name. It was known as Lloyd's of London until 1997, when it changed its name to Lloyd's.
A member of Lloyd's may be an individual member or a corporate member1. Members may be underwriting members or non-underwriting members. An underwriting member becomes a non-underwriting member from 31 December following the date on which they submit an application to resign from Lloyd's.
A Lloyd's underwriter is known as a Name and they underwrite liabilities up to an agreed amount by membership of a number of Lloyd's syndicates2.
This is discussed in detail in Division E5.6.
Gains and losses of Lloyd's members
Premium trust funds
The premium trust fund
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