Corporation Tax Act 2009 section 392

Exclusion of loan relationships of members of Lloyd's

Section 392 excludes certain loan relationships of corporate members of Lloyd's from the loan relationships rules in Part 5 of the Corporation Tax Act 2009, specifically where those relationships form part of a premium trust fund.

  • The section applies to any loan relationship held by a corporate member of Lloyd's
  • The general loan relationships rules in Part 5 do not apply where the rights, liabilities or securities under the loan relationship are assets forming part of the member's premium trust fund
  • The exclusion also covers liabilities attached to the premium trust fund
  • The terms "corporate member" and "premium trust fund" take their meanings from section 230(1) of the Finance Act 1994

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