Explanatory Notes

Corporation Tax Act 2010

2010 CHAPTER 4

3 March 2010

Introduction

Part 24: Corporation Tax Acts definitions etc

Chapter 2: Permanent establishments
Section 1146: The independent investment manager conditions

3268.This section sets out the conditions to be met if an investment manager in the United Kingdom is to be treated as an agent of independent status for the purposes of section 1142(1), and therefore not a permanent establishment, in relation to an investment transaction carried out on behalf of a non-UK resident company by the investment manager. It is based on paragraphs 1(1), 3 and 7(2) of Schedule 26 to FA 2003.