Part 14Income tax liability: miscellaneous rules
Chapter 1Limits on liability to income tax of non-UK residents
The independent investment manager conditions
820Meaning of “qualifying period”
(1)
This section applies for the purposes of this Chapter.
(2)
If section 819 applies for the purposes of section 813, a “qualifying period” means—
(a)
the tax year in which the transaction income is chargeable to income tax, or
(b)
a period of not more than 5 years comprising two or more tax years including that one.
(3)
If section 819 applies for the purposes of section 816, a “qualifying period” means—
(a)
the accounting period of the non-UK resident company in which the transaction in question is carried out, or
(b)
a period of not more than 5 years comprising two or more complete accounting periods including that one.