This rule mirrors that contained in ITA 2007, s. 835N, which is one of the conditions to be satisfied to prevent an investment manager from being treated as a UK representative of a non-resident (see ¶135-640) for the purposes of assessment of that non-resident’s income. SP1/01 (revised 20 July 2007) gives HMRC’s views on the operation of former FA 1995, s. 127 which was rewritten into the Income Tax Act 2007 and the 20% rule in particular.

To comply with this rule, the independent investment manager must satisfy two conditions in relation to a ‘qualifying period’:

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