Part 14Income tax liability: miscellaneous rules
Chapter 1Limits on liability to income tax of non-UK residents
The independent investment manager conditions
821Meaning of “relevant disregarded income”
(1)
This section applies for the purposes of this Chapter.
(2)
If section 819 applies for the purposes of section 813, the “relevant disregarded income” of the non-UK resident for the qualifying period is the total of the non-UK resident's income for the tax years comprised in the qualifying period which derives from the transactions mentioned in subsection (4).
(3)
If section 819 applies for the purposes of section 816, the “relevant disregarded income” of the non-UK resident company for the qualifying period is the total of the non-UK resident company's income for the accounting periods comprised in the qualifying period which derives from the transactions mentioned in F1subsection (5) .
(4)
The transactions referred to in F2subsection (2) are investment transactions—
(a)
carried out by the investment manager on the non-UK resident's behalf, and
(b)
in relation to which the independent investment manager conditions are met, ignoring the requirements of the 20% rule.
F3(5)
The transactions referred to in subsection (3) are transactions—
(a)
carried out by the investment manager on the non‑UK resident company’s behalf, and
(b)
in relation to which the investment manager does not fall to be treated as a permanent establishment of the non‑UK resident company, ignoring the requirements of the 20% rule.