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HMRC internal manual

Business Income Manual

Solicitors: Interest received on behalf of non-resident clients

S835C, S835E Income Tax Act 2007

A solicitor may receive interest on behalf of a person who is non-resident in the UK, either from a separate designated client account set up by the solicitor (see BIM65805) or an account set up by the client, The solicitor should not be taxed on this savings income as his own except in the unlikely event that he acts as the client’s ‘UK representative’ within the meaning of the above legislation. This would only be the case if the solicitor acts as the agent through whom the client carries on a trade in the UK. See INTM264020.