Ancillary trust fund assets and other 'Funds at Lloyd's' (FAL) are entitled to business property relief (BPR).
Assets usually have to be deposited as security with Lloyd's for any obligations in respect of underwriting business. The assets deposited qualify for 100% BPR, provided that they are not disproportionately large when compared with the risks underwritten. Generally, HMRC would not normally seek to restrict BPR if the value of the FAL is not greater than the minimum FAL requirement, which is equal to 40% of a Name's premium limit. However, this is only a guideline and HMRC would also consider the nature and risk of the business being underwritten and accept that these will affect the FAL1.
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Web page updated on 17 Mar 2025 13:47