Skip to content
Solved
SearchBrowse
Sign in

Contents

Official guidance
International Manual

INTM269000 · Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents - Contents

  • INTM269010 · Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: introduction
  • INTM269020 · Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: investment manager exemption: the legislation
  • INTM269030 · Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: investment manager exemption: effect on potential liabilities of UK representative
  • INTM269035 · Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents - investment manager exemption interaction with double taxation treaties and other domestic legislation
  • INTM269040 · Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: Lloyd’s members' agents
  • INTM269050 · Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: Brokers
  • INTM269060 · Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: investment manager exemption: conditions
  • INTM269065 · Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: investment manager exemption: consequences of not meeting conditions
  • INTM269070 · Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: investment managers: the definition of "investment transaction"
  • INTM269072 · Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: investment managers: "investment transaction": transactions in relevant contracts
  • INTM269074 · Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents - investment managers: "investment transaction": transactions resulting in a loan relationship or related transaction
  • INTM269076 · Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: investment managers: "investment transaction": transactions in units in collective investment schemes
  • INTM269079A · Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: investment managers - "investment transaction" - transactions in designated cryptoassets
  • INTM269080 · Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: investment managers: the independence test: examples of when satisfied
  • INTM269090 · Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: The independence test: meaning of "substantial part"
  • INTM269100 · Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: the independence test: meaning of "widely held"
  • INTM269105 · Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: the independence test: master/feeder structures
  • INTM269110 · Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: investment managers: the 20% rule
  • INTM269120 · Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: the 20% rule: qualifying period of no more than 5 years: example
  • INTM269130 · Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: the 20% rule: transparent and opaque funds
  • INTM269140 · Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: the 20% rule calculation: an example: an opaque fund
  • INTM269150 · Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: the 20% rule calculation: an example: a transparent collective investment scheme
  • INTM269155 · Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: the 20% rule: consequences of not meeting the rule
  • INTM269160 · Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: interaction of the independence test and the 20% rule
  • INTM269170 · Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: customary remuneration test
  • INTM269175 · Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: Customary remuneration test: avoidance
  • INTM269180 · Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: Limit to Income Tax charge on non-residents
  • INTM269190 · Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: Statement of Practice 1/01
  • INTM269200 · Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents - Statement of Practice 1/01 (as revised and reissued November 2016)
  • INTM269210 · Transactions carried out through UK investment managers, brokers: Statement of Practice 1/01 (yet to be reissued)
  1. Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents - Contents
  2. Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: Statement of Practice 1/01

INTM269190 | Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: Statement of Practice 1/01

From HM Revenue & Customs · International Manual

Purpose of SP 1/01

Statement of Practice 1/01 was originally issued on 6 June 2001 and gives guidance on how HMRC interprets and applies the provisions of the investment manager exemption scheme.

The statement of practice was revised and re-issued on 20 July 2007. The revised version took immediate effect, but non-residents and their investment managers could continue to rely upon the 6 June 2001 version up to 31 December 2009. This short term grandfathering arrangement was agreed with the industry to allow non-residents and their investment managers a transitional period.

As a result of consultation with the industry the statement of practice was updated on 03 November 2016 to take into account legislative change, including the expansion of the “white list”, which describes the types of investment transactions that may qualify for the Investment Manager Exemption, and to acknowledge the impact of certain changes in the regulatory environment.

The statement of practice was further revised with effect from 1 January 2026 to take into account further legislative changes to the PE rules, including the investment manager exemption.

Treatment of investment managers and their overseas clients (HMRC website)

PreviousNext
PrivacyTerms