Part 24Corporation Tax Acts definitions etc
Chapter 2Permanent establishments
Lloyd's agents
1151Lloyd's agents
(1)
This section applies if a transaction is carried out on behalf of a non-UK resident company in the course of the company's trade by a person in the United Kingdom acting as a members' agent or managing agent at Lloyd's.
(2)
In relation to the transaction, the person is regarded for the purposes of section 1142(1) as an agent of independent status acting in the ordinary course of the person's business if conditions A, B and C are met.
(3)
Condition A is that the non-UK resident company is a member of Lloyd's.
(4)
Condition B is that the transaction is carried out in the course of the company's underwriting business.
(5)
Condition C is that the person acting on behalf of the company in relation to the transaction acts as members' agent or as managing agent of the syndicate in question.
(6)
For the purposes of this section—
(a)
a non-UK resident company is a member of Lloyd's if it is a corporate member within the meaning of Chapter 5 of Part 4 of FA 1994, and
(b)
“members' agent” and “managing agent” are to be read in accordance with section 230 of that Act.