UK tax on Investment Managers and non-resident investors

How Investment Manager Exemption identifies if overseas investors are liable to tax on transactions conducted by a UK Investment Manager.

The Investment Manager Exemption

One of the key components in the UK’s continuing attraction for non-resident investors (including hedge funds) is their ability to appoint UK-based investment managers without creating a risk of UK taxation for themselves. HM Revenue and Customs (HMRC) is committed to maintaining this environment by offering the Investment Manager Exemption.

Through a series of qualifying tests, the Investment Manager Exemption ensures that:

  • overseas investors are not charged to UK tax in relation to investment transactions conducted on their behalf
  • any fees received by a UK resident investment manager for services performed for the non-resident are fully chargeable to UK tax

HMRC has published a Statement of Practice SP1/01 on how the Investment Manager Exemption works and you can find more detailed guidance in HMRC’s International Manual.

Who to contact for further advice

If you have a question about the Investment Manager Exemption you can contact HMRC in writing:

Alexander Duric
286 Euston Road

Alternatively you can contact by email:

Published 29 May 2014
Last updated 12 October 2017 + show all updates
  1. The contact details for who to contact for further advice have been updated.
  2. New contact details added
  3. Who to contact for further advice details have been changed.
  4. First published.