Part 14Income tax liability: miscellaneous rules
F1Chapter 2CIncome tax obligations and liabilities imposed on UK representatives
Annotations:
Amendments (Textual)
835YF2Meaning of “independent agent”
1
In this Chapter “independent agent”, in relation to a non-UK resident (“X”), means a person who is the UK representative of X in respect of any agency in which the person is acting on behalf of X in an independent capacity.
2
For this purpose a person does not act in an independent capacity on behalf of X unless the relationship between them, having regard to its legal, financial and commercial characteristics, is a relationship between persons carrying on independent businesses dealing with each other at arm's length.
Pt. 14 Ch. 2C inserted (with effect in accordance with s. 381(1) of the amending Act) by Taxation (International and Other Provisions) Act 2010 (c. 8), s. 381(1), Sch. 6 para. 18 (with Sch. 9 paras. 1-9, 22)