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HMRC internal manual

International Manual

Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: investment managers: the definition of "investment transaction"

The Investment Transactions (Tax) Regulations 2014, as applied and modified by the Investment Manager (Investment Transactions) Regulations 2014 specify the types of transaction that are an ‘investment transaction’ for the purposes of ITA07/S827(2) and CTA10/S1150. The Regulations provide that an ‘investment transaction’ is any transaction:

In stocks or shares;

In a ‘relevant contract’ (see INTM269072);

Which results in the non-resident becoming party to a ‘loan relationship’ or a ‘related transaction’ (see INTM269074);

In units in a collective investment scheme (see INTM269076);

In securities (see INTM269078);

Consisting in the buying or selling of foreign currency; or

In a carbon emission trading product (see INTM269079).

In rights under a life insurance policy

The regulations came into force on 8 April 2014 and have effect in relation to transactions entered into on or after that date. The regulations replaced the Investment Manager (Specified Transactions) Regulations 2009 which had effect for the tax year 2009-10 and subsequent tax years (for income tax), and in relation to accounting periods ending on or after 12 May 2009 (for corporation tax).

Copies of the regulations can accessed through the links below

The Investment Manager (Investment Transactions) Regulations 2014

The Investment Transactions (Tax) Regulations 2014

Although excluded from the usual requirement to be made by way of statutory instrument, and therefore not carrying an “SI” number, the Investment Manager (Investment Transactions) Regulations 2014 are nevertheless secondary legislation with full statutory force.