»Ê¹ÚÌåÓýapp

»Ê¹ÚÌåÓýapp rules for terminal loss relief (‘TLRâ€�) when an individual ceases to be a member of the SLP mirror the TLR rules (LLM5390) which apply when an individual ceases to be a member of Lloyd’s. Regulation 10(2) SI1997/2681 deems the individual partner’s trade to cease on 5 April of the final tax year in which his share of profits from the partnership includes the results of one or more syndicates. »Ê¹ÚÌåÓýapp loss of the last 12 months is then the retiring partner’s allocated share of the tax-adjusted loss of the accounting period ending on 31 December immediately before the date of deemed cessation. »Ê¹ÚÌåÓýapp loss is then available for relief against underwriting profits of the three preceding tax years, taking a later year before an earlier year, in the same way as for terminal losses sustained in any other trade under ICTA88/S388 and ITA07/S89.

In the example in LLM6100 the final tax year that the retiring partner has syndicate results in his share of the partnership profit is 2008-09. »Ê¹ÚÌåÓýapp deemed date of cessation is 5 April 2009 and the loss of the last 12 months is his share of the tax-adjusted loss of accounting period ending 31 December 2008. »Ê¹ÚÌåÓýapp loss can be set against the retiring partner’s other income of 2007-08, 2006-07 or 2005-06, taking a later year before an earlier year.