The committee discussed the implications of the proposed US tax bill for the Lloyd’s market, including potential changes to BEAT, withholding tax and the impact of Section 899, noting significant financial and administrative risks should the UK be designated a discriminatory foreign country. The strategic importance and continued benefits of the US Closing Agreement were emphasised, alongside ongoing engagement with UK Treasury and monitoring of legislative developments.

Members also reviewed Lloyd’s proposed submissions to HMRC on Pillar 2 guidance, transfer pricing, permanent establishment and diverted profits tax, highlighting concerns around increased administrative burden, definitions of syndicates, and double tax relief. Further updates were provided on PE certification, South Africa and India tax developments, VAT reform and e-invoicing consultations, and the transition to QMA Delta, with members invited to contribute to consultation responses and working groups.