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Corporation Tax Act 2010
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1147Investment managers: the 20% rule
This section has no associated Explanatory Notes
(1)The requirements of the 20% rule are met if conditions A and B are met.
(2)Condition A is that, in relation to a qualifying period, it has been or is the intention of the investment manager and the persons connected with the investment manager that at least 80% of the non-UK resident company’s relevant disregarded income should consist of amounts to which none of them has a beneficial entitlement.
(3)Condition B is that, so far as there is a failure to fulfil that intention, that failure—
(a)is attributable (directly or indirectly) to matters outside the control of the investment manager and persons connected with the investment manager, and
(b)does not result from a failure of any of them to take such steps as may be reasonable for mitigating the effect of those matters in relation to the fulfilment of that intention.
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