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Home / Simons-Taxes /Personal and employment tax /Part E5 Special classes of individual /Division E5.6 Lloyd's underwriters /Lloyd's underwriters—losses / E5.625A Restriction of loss relief—Scottish limited partnerships and limited liability partnerships
Commentary

E5.625A Restriction of loss relief—Scottish limited partnerships and limited liability partnerships

Personal and employment tax

Member partnerships at Lloyd's can be Scottish limited partnerships (SLPs) or limited liability partnerships (LLPs)1.

The legal structure of these differ in that Scottish limited partnerships have both limited and general members, while LLPs have only limited partners2. Underwriting members will be limited partners (see E5.608).

Restrictions as outlined below apply to limited partners, so affecting LLPs and SLPs.

General restrictions on trading loss relief

Income tax relief for trading losses of certain classes of partner is restricted by the rules in ITA 20073.

The

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