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Home / Simons-Taxes /Personal and employment tax /Part E5 Special classes of individual /Division E5.6 Lloyd's underwriters /Taxation of underwriting income and gains / E5.620A Taxation of Scottish limited partnerships
Commentary

E5.620A Taxation of Scottish limited partnerships

Personal and employment tax

Scottish limited partnerships provide a corporate, limited liability, vehicle for participation at Lloyd's while retaining the tax treatment of trading through a partnership for the individual partners.

Scottish partnerships (unlike English partnerships) have a legal identity separate to that of the individual partners1. This means that they are able to satisfy the requirement at Lloyd's for members to personally underwrite business2.

Until the creation of UK-wide Limited liability partnerships, they provided the only route to satisfy the Lloyd's requirement through a partnership vehicle.

The tax treatment of Scottish limited partnerships follows the general principles of partnership taxation, but also takes into account the specific Lloyd's rules in the Lloyd's Underwriters

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Web page updated on 17 Mar 2025 17:24