Lloyd’s has issued a statement commending the decision to remove Section 899 from the Republican reconciliation bill—a provision that, if enacted, could have imposed significant additional taxes on the U.S. income of businesses domiciled outside the country.
UK businesses had characterized Section 899 as a form of "retaliatory tax measures,” targeting them unfairly.
“We are very grateful for the chancellor’s leadership, working with her G-7 Finance Minister colleagues, to secure the announcement from the United States Treasury and Congress that Section 899 has been removed from the reconciliation bill,” said Lloyd’s Chair Sir Charles Roxburgh, in a statement.
“This greatly supports not only Lloyd’s business in the United States but all British companies with interests in the United States and will enable international investment in the United States to serve domestic businesses and communities,” Roxburgh continued.
“Lloyd’s has been providing insurance capacity to support the economy of the United States — our largest market — for over a century, and we are pleased to continue to do so,” he said.
With Section 899 now removed from the so-called “One Big Beautiful Bill Act” (OBBBA), the UK and other G-7 nations can move forward in shaping a coordinated approach to the global minimum tax and addressing aggressive tax avoidance—free from the shadow of a proposed retaliatory measure, according to a June 28 statement from the UK Treasury and Chancellor of the Exchequer Rachel Reeves.
“I will always represent the best interests of British businesses on the world stage. Today’s agreement provides much-needed certainty and stability for those businesses after they had raised their concerns,” Reeves said.
“The G7 agrees there is work to be done in tackling aggressive tax planning and avoidance and ensuring a level-playing field. The right environment for this work to happen is without the prospect of retaliatory taxation hanging over these talks, so the removal of Section 899 is welcome,” she added.“The US commitment to drop retaliatory tax measures proposed in the One Big Beautiful Bill removes a major source of uncertainty for UK-headquartered multinationals,” according to Rain Newton-Smith, chief executive, Confederation of British Industry, in the Treasury statement.
“The CBI has been clear – there are no winners in an economic standoff. Avoiding disruption to transatlantic investment, financial flows and jobs benefits both the US and UK economies,” Newton-Smith said. “Avoiding disruption to transatlantic investment, financial flows and jobs benefits both the US and UK economies.”
Newton-Smith noted, however, that “uncertainty remains around the bill’s final passage and other potential Congressional actions later down the line alongside the UK’s Digital Services Tax under scrutiny….”
“Looking ahead, global tax rules must now be rebalanced through multilateral agreement while ensuring UK companies remain competitively positioned. This is a pivotal opportunity for the OECD to deliver a genuinely simpler, fairer regime – one that goes much further in reducing excessive compliance burdens and upholds a level playing field for all,” she added.
