Part 14Income tax liability: miscellaneous rules
Chapter 1Limits on liability to income tax of non-UK residents
The independent investment manager conditions
821Meaning of “relevant disregarded income”
1
This section applies for the purposes of this Chapter.
2
If section 819 applies for the purposes of section 813, the “relevant disregarded income” of the non-UK resident for the qualifying period is the total of the non-UK resident's income for the tax years comprised in the qualifying period which derives from the transactions mentioned in subsection (4).
3
If section 819 applies for the purposes of section 816, the “relevant disregarded income” of the non-UK resident company for the qualifying period is the total of the non-UK resident company's income for the accounting periods comprised in the qualifying period which derives from the transactions mentioned in F1subsection (5) .
4
The transactions referred to in F2subsection (2) are investment transactions—
a
carried out by the investment manager on the non-UK resident's behalf, and
b
in relation to which the independent investment manager conditions are met, ignoring the requirements of the 20% rule.
F35
The transactions referred to in subsection (3) are transactions—
a
carried out by the investment manager on the non‑UK resident company’s behalf, and
b
in relation to which the investment manager does not fall to be treated as a permanent establishment of the non‑UK resident company, ignoring the requirements of the 20% rule.