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HMRC internal manual

International Manual

From
HM Revenue & Customs
Updated
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Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: the independence test: master/feeder structures

Where the investment manager manages an opaque master fund, e.g. a company which has feeder funds, then the independence test will be applied as if the master fund were transparent, by looking at the beneficial ownership of each feeder fund to determine whether the master fund is independent.

Similarly, if the investment manager acts for one or more sub-funds owned by an umbrella fund it is the beneficial ownership of the latter that will determine whether the independence test is met.