SCHEDULES

SCHEDULE 6UK Representatives of non-UK residents

Part 1New Chapters 2B and 2C of Part 14 of ITA 2007

7

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)).