Income Tax Act 2007 section 835K

Lloyd's agents

Section 835K ensures that Lloyd's agents acting for non-UK resident Lloyd's members are not treated as their UK representatives for tax purposes in relation to underwriting income.

• This section applies where a non-UK resident is a member of Lloyd's and receives income from their underwriting business that would otherwise fall within the UK representative rules
• A person who has acted as the non-UK resident's members' agent, or as the managing agent of the relevant syndicate, is not treated as the non-UK resident's UK representative in relation to that underwriting income
• This prevents Lloyd's agents from being drawn into UK tax obligations on behalf of non-UK resident members simply by virtue of their agency role
• The definitions of "member of Lloyd's", "members' agent" and "managing agent" are taken from the Finance Act 1993