SCHEDULES

SCHEDULE 26U.K.Non-resident companies: transactions through broker, investment manager or Lloyd’s agent

IntroductionU.K.

1(1)This Schedule makes provision about transactions carried out on behalf of a company that is not resident in the United Kingdom (a “non-resident company”), in the course of that company’s trade, by a person in the United Kingdom acting as—U.K.

(a)a broker (paragraph 2),

(b)an investment manager (paragraphs 3 to 5), or

(c)a members' or managing agent at Lloyd’s (paragraph 6).

(2)The provisions of this Schedule supplement—

(a)section 148(3) (meaning of “permanent establishment”: not to include independent agent), and

(b)section 151(2)(c) (limit on income tax chargeable on non-resident company: income arising from transactions carried out through independent agent).