Part 14Income tax liability: miscellaneous rules
Chapter 1Limits on liability to income tax of non-UK residents
The independent investment manager conditions
820Meaning of “qualifying period”
1
This section applies for the purposes of this Chapter.
2
If section 819 applies for the purposes of section 813, a “qualifying period” means—
a
the tax year in which the transaction income is chargeable to income tax, or
b
a period of not more than 5 years comprising two or more tax years including that one.
3
If section 819 applies for the purposes of section 816, a “qualifying period” means—
a
the accounting period of the non-UK resident company in which the transaction in question is carried out, or
b
a period of not more than 5 years comprising two or more complete accounting periods including that one.