Taxation (International and Other Provisions) Act 2010 section 454

Members of Lloyd's

Section 454 ensures that corporate members of Lloyd's have their underwriting business income and derivative contracts properly included within the corporate interest restriction rules, by adjusting how certain references in this Part are to be read.

• This section applies specifically to bodies corporate that carry on underwriting business as members of Lloyd's.
• References to amounts brought into account as trading credits or debits under the normal loan relationship and derivative contract rules are instead read as references to amounts brought into account under the special Lloyd's tax provisions in section 219 of the Finance Act 1994.
• References to derivative contracts are read more broadly, so that relevant contracts forming part of a Lloyd's premium trust fund are included as derivative contracts, even though section 226(3) of the Finance Act 1994 would normally exclude them.
• The overall effect is that interest and similar amounts arising from a corporate Lloyd's member's underwriting business are captured within the definition of tax-interest for the purposes of the corporate interest restriction.