SCHEDULES

SCHEDULE 6UK Representatives of non-UK residents

Part 1New Chapters 2B and 2C of Part 14 of ITA 2007

14

After section 835O insert—

835PTreatment of transactions where 20% rule not met

1

This section applies in the case of an investment transaction in relation to which the independent investment manager conditions are met, except for the requirements of the 20% rule.

2

This Chapter has effect as if the requirements of that rule were met in relation to the transaction, but only in relation to so much of the transaction income in relation to the transaction (see section 835I(2) and (3)) as does not represent an amount—

a

which is relevant disregarded income of the non-UK resident, and

b

to which the investment manager or a person connected with the investment manager has or has had any beneficial entitlement.