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HMRC internal manual

International Manual

HM Revenue & Customs
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Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: interaction of the independence test and the 20% rule

All of the five conditions (INTM269060) of the investment manager’s exemption provisions have to be satisfied before the exemption can apply. The independence test (INTM269080) should be applied completely separately before the application of the 20% rule (INTM269110) in each case.