Fidentia Services LLP provides an administrative service for Namecos and Limited Liability partnerships (LLPs) underwriting at Lloyd's.
Lloyd’s profits are taxed on a three-year time lag. The underwriting result (net of expenses) for the 2025 calendar year will be taxed in 2028 – year to 31 December 2028 for Namecos, and tax year 2028/29 for LLP members.
Sales of capacity are subject to capital gains tax in the (tax) year of sale.
A change in rate for business asset disposal relief came into effect from April 2025. Should you wish to sell your vehicle out of personal ownership, the gain will now be charged at 14%, up from 10%, on the first £1m of qualifying gains. This increases further to 18% in April 2026. The rate after the first £1m has also increased from 20% to 24%.
Whilst the LLP is a limited liability entity, it does not exist for tax purposes.
Therefore, for LLP members, the tax treatment is the same as for any partnership – each member is taxed on their share of the profits, regardless of whether these are withdrawn from the LLP, at their highest marginal rate of tax. They will also be liable to Class 2 and Class 4 National Insurance Contributions, where applicable.
Legislation, enacted in 2014, restricts the amount of LLP profits that can be allocated to non-natural members of LLPs (i.e. trusts or companies), where the LLP also contains individuals as members. If you would like to have a non-natural person as a member of a LLP, this legislation must be considered in detail before setting up a structure such as this.
Converting Names may have an existing Special Reserve Fund (SRF). SRF may not be added to from LLP profits. In principle, it will be released once all open years for the unlimited Name have closed and will be taxable in full at that time.
The income earned from the LLP will be ‘pensionable’ income for the LLP members, under current pension legislation. However, from April 2027, pensions will start to be included in the individual’s estate, taking that pot from a tax rate of 0% to 40%. This guidance is not final as the government has not yet provided legislation. Please note that we will continue to review the position.
A Nameco is a limited liability vehicle. However, a Nameco has a separate tax identity of its own and, as a result, pays corporation tax on its underwriting profits.
Currently, if a Nameco makes taxable profits of less than £50,000, the profits will only be charged to Corporation tax at a rate of 19%, whereas a Nameco making in excess of £250,000 will then pay Corporation Tax at a rate of 25% on the whole taxable profits.
A marginal relief rate between 19% and 26.5% will apply for those with taxable profits between £50,000 and £250,000. Furthermore, where Nameco’s are in an associated or corporate group, the £50,000 and £250,000 thresholds will be reduced based on the number of companies that the Nameco is ‘connected’ to.
As the Nameco is a separate legal entity with its own tax liability, the post-tax profits in the company can either be used to:
