Explanatory note

These Regulations make provision for the application of double taxation relief in relation to the income tax liability of an individual who is a member of Lloyd’s in respect of the profits or losses of his underwriting business.

Regulation 1 provides for citation, commencement and effect, and regulation 2 for interpretation.

Regulation 3 provides for double taxation relief to be given by pooling the foreign tax paid on all income that is taken into account in computing the profits or losses of a member’s underwriting business for a year of assessment.

Regulation 4 makes provision for allocating foreign tax attributable to syndicate profits of a member (other than United States or Canadian tax) to years of assessment, and regulation 5 makes provision for allocating foreign tax attributable to non-syndicate profits of a member (other than United States or Canadian tax) to years of assessment.

Regulations 6 and 7 provide for the allocation of United States tax and Canadian tax to years of assessment.

Regulation 8 provides for the allocation of additional payments of foreign tax for any underwriting year to a year of assessment.

Regulation 9 makes provision for the treatment of refunds of foreign tax in relation to double taxation relief.