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Individual Names

The value of an individual Name’s Lloyd’s interests normally qualifies for100% relief under IHTA84/S105 (1)(a).

Scottish limited partnerships and Limited Liability Partnerships

An interest in a trading partnership, as with a corporate vehicle, should attract 100%relief as should Funds at Lloyd’s (FAL) assets utilised by an SLP or LLP throughinteravailability.

Corporate members

‘Corporate member� here refers to incorporated companies that are members ofLloyd’s, including ‘Namecos�. In broad terms, companies are not subject toIHT. However, shareholdings in corporate vehicles should attract business property relief(BPR) of 100% where unquoted or 50% for shares or securities giving control of a quotedcompany.

A shareholding in a Nameco will qualify for BPR at 100% providing the two-year ownershipcondition of IHTA84/S106 is satisfied.

As a general rule, FAL assets do not qualify for BPR during the first two years of a newbusiness. However, special rules (IHTA84/S107) apply for replacement property and,provided a Name transfers the whole of his bespoke business to a new corporate business,the new business will be treated as replacement property.

In the situation where a Name was in the process of transferring their entire personalbusiness into a Nameco at the date of death, the shares allotted in return for thetendering of eligible capacity will be treated as replacement property within the meaningof IHTA84/S107 and BPR at 100% will be available.