Guidance

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
HMRC
286 Euston Road
London
NW1 3UH

Alternatively you can contact by email: alexander.duric@hmrc.gsi.gov.uk

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.
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