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The legislation¹ provides relief where a Lloyd's Name converts to limited liability underwriting, or where a Lloyd's partnership converts to a company².

The conversion reliefs apply on the conversion of an individual Name to limited liability underwriting, through a corporate member of Lloyd's (typically a Nameco, for background see E5.607), a Scottish limited partnership (see E5.608), or a limited liability partnership (see E5.609.) The Lloyd's regulations and system of accounting, require the transfer of underwriting to take place over an extended period. The conversion rules broadly replicate the tax reliefs for other unincorporated businesses on conversion to a company or a partnership.

The relief permits any unused balance of the Name's underwriting losses to be carried forward and set against profits of the underwriting business carried on by the successor company or partnership. Further reliefs available on conversion to underwriting through a successor company are covered at E5.635.

Relief for the carry-forward of losses against the income from a successor company is available in respect