Part 14Income tax liability: miscellaneous rules
Chapter 1Limits on liability to income tax of non-UK residents
The independent investment manager conditions
819Investment managers: the 20% rule
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'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 by 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.
4
This section needs to be read with—
section 820 (meaning of “qualifying period”),
section 821 (meaning of “relevant disregarded income”), and
section 822 (meaning of “beneficial entitlement”).