Related Commentary  

819(1)  The requirements of the 20% rule are met if conditions A and B are met.

819(2)  Condition A is that in relation to a qualifying period it has been or is the intention of the investment manager and the persons connected with the investment manager that at least 80% of the non-UK resident's relevant disregarded income should consist of amounts to which none of them has a beneficial entitlement.

819(3)  Condition B is that, so far as there is a failure to fulfil that intention, that failure–

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