This Clause amends Section 155 of the Taxation of Chargeable Gains Act 1992 to extend roll-over relief to Lloyd’s syndicate rights, whether they are held directly or through a Members’ Agent Pooling Arrangement (MAPA). The Clause applies to disposals and acquisitions of syndicate rights that take place on or after 6 April 1999.

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Subsection (1) amends Section 155 of the Taxation of Chargeable Gains Act 1992 to create a new class of qualifying asset for roll-over relief. It is numbered Class 8 because fish quota was recently added to section 155 as Class 7 by secondary legislation. Syndicate rights held directly are included under Head A while Head B covers syndicate rights held within a MAPA .

Subsection (2) applies the new rules to acquisitions or disposals of syndicate rights that take place on or after 6 April 1999.

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Capital gains tax roll-over relief allows a trader to defer a capital gain arising on the disposal of a business asset, as long as he/she reinvests the proceeds of the sale in another business asset.

In 1995 Lloyd's changed its rules to allow syndicate rights to be bought and sold for the first time. This enabled Lloyd's members to realise capital gains and losses on their disposals of syndicate rights.

Lloyd’s members can participate in underwriting syndicates only to the extent that they possess the relevant rights to do so. Ownership of syndicate rights is therefore fundamental to their ability to exercise their trade of underwriting. Thus syndicate rights are consistent with other classes of assets that qualify for CGT roll-over relief.