Relief for gifts of business assets is available when business assets are disposed ofother than in bargains at arms length (TCGA92/S165). Where syndicate capacityreverts to a managing agent, this may be treated as a bargain otherwise than at armslength if the Name and managing agent are connected persons. Under the currentLloyds rules for transferring syndicate capacity, all other transfers are throughthe auction process or bilateral arrangements, and will generally be arms lengthbargains.

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