How the Investment Manager Exemption identifies if overseas investors are liable for tax on transactions conducted by a UK investment manager.
The Investment Manager Exemption
One of the reasons for the UK attracting non-resident investors (including hedge funds) is their ability to appoint UK based investment managers without creating a risk of UK taxation for themselves.
HMRC is committed to maintain this environment by offering the Investment Manager Exemption.
The Investment Manager Exemption uses qualifying tests to make sure:
- overseas investors are not charged to UK tax for 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’s International Manual which includes Statement of Practice SP1/01 has more information about how the Investment Manager Exemption works.
You can find more information in HMRC’s International Manual.
Who to contact for further advice
Write to HMRC if you have a question about the Investment Manager Exemption:
10 South Colonnade
You can also send an email: firstname.lastname@example.org.