After section 835H insert—

“835IInvestment managers

(1)

This section applies if a non-UK resident carries on (alone or in partnership) a business through an investment manager in the United Kingdom.

(2)

The investment manager is not the UK representative of the non-UK resident in relation to an amount within section 835E(2) if—

(a)

the amount is transaction income in relation to an investment transaction carried out through the investment manager in the United Kingdom on behalf of the non-UK resident, and

(b)

the independent investment manager conditions are met in relation to the investment transaction (see section 835M).

(3)

In subsection (2) “transaction income”, in relation to a transaction carried out through an investment manager in the United Kingdom on behalf of a non-UK resident, has the same meaning as in Chapter 1 (see section 814(5)).”