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.