Commentary

I7.172 BPR and Lloyd's underwriters

IHT, trusts and estates

I7.172 BPR and Lloyd's underwriters

I7.172 BPR and Lloyd's underwriters

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 what is now 100% BPR, provided that they are not disproportionately large 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 limit1. Any excess over what is appropriate

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