There is a possibility that if a syndicate operates as a limited liability company the Inland Revenue could follow this course of action. There would appear to be no risk where the syndicate operates as a "partnership" at this time, always assuming that the "partnership" does not realise a profit on its activities. In such matters the Inland Revenue are really very helpful and reasonable people and if this is a concern you would do as well to explain the circumstances to one of their officers and I suspect would be able to reach agrement between you.