Income Tax Act 2007 (c. 3)

Part 14 U.K. Income tax liability: miscellaneous rules

Chapter 1 U.K. Limits on liability to income tax of non-UK residents

The independent investment manager conditions U.K.

822 Meaning of “beneficial entitlement” U.K.

(1) This section applies for the purposes of this Chapter.

(2) A person has a “beneficial entitlement” to relevant disregarded income if the person has or may acquire a beneficial entitlement that is, or would be, attributable to the relevant disregarded income as a result of having an interest or other rights mentioned in subsection (3).

(3) The interests and rights referred to in subsection (2) are—

(a) an interest (whether or not an interest giving a right to an immediate payment of a share in the profits or gains) in property in which the whole or any part of the relevant disregarded income is represented, or

(b) an interest in, or other rights in relation to, the non-UK resident.