Part 14Income tax liability: miscellaneous rules
Chapter 1Limits on liability to income tax of non-UK residents
The independent investment manager conditions
823Treatment of transactions where requirements of 20% rule not met
1
This section applies in the case of an investment transaction in relation to which the independent investment manager conditions are met, except for the requirements of the 20% rule.
2
This Chapter has effect as if the requirements of that rule were met in relation to the transaction but only in relation to—
a
so much of the transaction income of the non-UK resident as falls within subsection (3), if this section applies for the purposes of section 813, or
b
so much of the income of the non-UK resident company deriving from the transaction as falls within subsection (3), if this section applies for the purposes of section 816.
3
Income falls within this subsection if it does not represent income—
a
which is relevant disregarded income of the non-UK resident, and
b
to which the investment manager or a person connected with the investment manager has or has had any beneficial entitlement.