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Income Tax Act 2007
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823Treatment of transactions where requirements of 20% rule not met
This section has no associated Explanatory Notes
(1)This section applies in the case of an investment transaction in relation to which the independent investment manager conditions are met, except for the requirements of the 20% rule.
(2)This Chapter has effect as if the requirements of that rule were met in relation to the transaction but only in relation to—
(a)so much of the transaction income of the non-UK resident as falls within subsection (3), if this section applies for the purposes of section 813, or
(b)so much of the income of the non-UK resident company deriving from the transaction as falls within subsection (3), if this section applies for the purposes of section 816.
(3)Income falls within this subsection if it does not represent income—
(a)which is relevant disregarded income of the non-UK resident, and
(b)to which the investment manager or a person connected with the investment manager has or has had any beneficial entitlement.
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