E5.633 Gains And Losses On Disposals Within The Special Reserve Fund

Home / Simons-Taxes /Personal and employment tax /Part E5 Special classes of individual /Division E5.6 Lloyd's underwriters /Capital gains and losses / E5.633 Gains and losses on disposals within the special reserve fund

Commentary

Personal and employment tax

Special reserve funds are only held by individual Names¹.

Gains or losses on the disposal of assets in a member's special reserve fund are exempt from capital gains tax². However, as the member is treated as absolutely entitled as against the trustees to the assets in their special reserve fund³, any purchase of an asset

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B3.325 General exclusions—first-year qualifying expenditure

I7.504 Designation for the conditional exemption

B2.306 General tests for distinguishing between capital and revenue expenditure

A4.214 Claims following further assessments—income tax and capital gains tax

B5.820 Charity's profits of trade—general liability to income tax

E8.271 Liability for Class 1A contributions

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