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HMRC internal manual

International Manual

Non-residents trading in the UK: through UK investment managers, brokers or Lloyd’s agents: Statement of Practice 1/01

Purpose of SP 1/01

Statement of Practice 1/01 was originally issued on 6 June 2001 and gives guidance on how HMRC interprets and applies the provisions of the investment manager exemption scheme.

The statement of practice was revised and re-issued on 20 July 2007. The revised version took immediate effect, but non-residents and their investment managers could continue to rely upon the 6 June 2001 version up to 31 December 2009. This short term grandfathering arrangement was agreed with the industry to allow non-residents and their investment managers a transitional period.

As a result of consultation with the industry the statement of practice was updated on 03 November 2016 to take into account legislative change, including the expansion of the “white list”, which describes the types of investment transactions that may qualify for the Investment Manager Exemption, and to acknowledge the impact of certain changes in the regulatory environment.

Treatment of investment managers and their overseas clients (HMRC website)