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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 (as revised and reissued November 2016)

Text of SP 1/01

The material linked to from this page is the text of Statement of Practice 1/01 as updated on 03 November 2016. The statement of practice gives guidance on how HMRC interpret and apply the provisions of the investment manager exemption scheme.

This updated version of the statement of practice replaces the revised and re-issued version issued of 20 July 2007. The July 2007 version was a response to both legislative change - primarily, the introduction in Finance Act 2003 of new and separate provisions for non-residents potentially within the charge to corporation tax (see INTM269020) - and to developments in the investment management sector.

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 )