{
  "url": "https://openlegislation.uk/lloyds-underwriters-double-taxation-relief-regulations-1997/note",
  "json_url": "https://openlegislation.uk/lloyds-underwriters-double-taxation-relief-regulations-1997/note.json",
  "legislation": "uksi/1997/405",
  "legislation_title": "The Lloyd’s Underwriters (Double Taxation Relief) Regulations 1997",
  "legislation_url": "https://openlegislation.uk/lloyds-underwriters-double-taxation-relief-regulations-1997",
  "path": "note",
  "kind": "note",
  "number": null,
  "heading": "Explanatory note",
  "text": "(This note is not part of the Regulations)\nThese 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.\nRegulation 1 provides for citation, commencement and effect, and regulation 2 for interpretation.\nRegulation 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.\nRegulation 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.\nRegulations 6 and 7 provide for the allocation of United States tax and Canadian tax to years of assessment.\nRegulation 8 provides for the allocation of additional payments of foreign tax for any underwriting year to a year of assessment.\nRegulation 9 makes provision for the treatment of refunds of foreign tax in relation to double taxation relief.",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/uksi/1997/405/note",
    "retrieved_at": "2026-10-29T12:24:59.448296+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}