Part 14

Income tax liability: miscellaneous rules
Chapter 1

Limits on liability to income tax of non-UK residents

The independent investment manager conditions

Meaning of “beneficial entitlement”
822
1
This section applies for the purposes of this Chapter.
2
A person has a “beneficial entitlement” to relevant disregarded income if the person has or may acquire a beneficial entitlement that is, or would be, attributable to the relevant disregarded income as a result of having an interest or other rights mentioned in subsection (3).
3
The interests and rights referred to in subsection (2) are—
a
an interest (whether or not an interest giving a right to an immediate payment of a share in the profits or gains) in property in which the whole or any part of the relevant disregarded income is represented, or
b
an interest in, or other rights in relation to, the non-UK resident.
Pt. 14 Ch. 1 excluded by 2005 c. 5, s. 608X(3)(a) (as inserted (with effect in accordance with Sch. 3 para. 7 of the amending Act) by Finance Act 2019 (c. 1), Sch. 3 para. 4)