Revenue Tax Briefing

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Revenue Tax Briefing Issue 26, April 1997

Lloyds Underwriters - Irish Names

The following changes in relation to retirement annuity premium relief and Irish accountancy fees have been agreed by Revenue with the Irish Taxation advisor to Lloyds and with Lloyd’s Taxation Department.

Retirement Annuity Premium Relief

For tax years up to and including 1995/96 a Name’s underwriting profits are only treated as earned income for retirement annuity purposes, where that Name is a “working Name” - paragraph 3.8 of Tax Briefing Issue 19 refers.

From and including the 1996/97 tax year a Name’s underwriting profits and income arising from Funds at Lloyd’s will be treated as earned income for retirement annuity purposes without reference to the concept of “working Name”.

Allowance for Irish Accountancy Fees

Whilst recognising that UK accountancy fees deductible in the UK cover the allowable accountancy expenses required to produce the UK taxable result, it is acknowledged that additional work is necessary in Ireland to adjust the UK figures for the purposes of reporting in Ireland. For tax years up to and including 1995/96 an allowance based on the UK scale fee was permitted whereby one-third of the permitted UK scale was allowed as an expense in addition to the scale charge. However, the UK scale fee regime is being phased out in the UK and will completely cease after the 1993 year of account. Consequently, from and including the 1996/97 tax year a deduction may be claimed for Irish tax purposes for Irish accountancy expenses incurred in arriving at the Irish Lloyds taxable figures on an actual basis, subject to any necessary apportionment where any such expenses also relate to non-Lloyds related aspects.

Lloyds Conversion Rates

For Lloyds accounts the conversion of sterling should be calculated by reference to the sterling rate on the last market day of the calendar year in which the account is closed.

The selling rate for 1996 was


= IR£0.9926

For reference earlier years were as follows:


Stg£1 = IR£0.9687


Stg£1 = IR£0.9995