The Investment Manager Exemption

One of the key components in the UK's continuing attraction for non-resident investors (including hedge funds) is their ability to appoint UK-based investment managers without creating a risk of UK taxation for themselves. HM Revenue & Customs (HMRC) is committed to maintaining this environment by offering the Investment Manager Exemption.

This guide briefly describes the Investment Manager Exemption, explains where to get further guidance and who to contact if you need further advice.

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What the Investment Manager Exemption achieves

Through a series of qualifying tests, the Investment Manager Exemption ensures that:

  • overseas investors are not charged to UK tax in relation to investment transactions conducted on their behalf
  • any fees received by a UK resident investment manager for services performed for the non-resident are fully chargeable to UK tax

HMRC has published a Statement of Practice, SP1/01, on how the Investment Manager Exemption works and there's also full guidance available in the links to the International Manual below.

Go to Statement of Practice SP1/01

Read about non-residents trading in the UK through UK investment managers, brokers or Lloyd's agents

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Who to contact for further advice

Please send any questions about the Investment Manager Exemption to:

Adam Cartwright
HM Revenue & Customs
CTIAA Business International
100 Parliament Street
London
SW1A 2BQ

You can also email using the link below.

Contact Adam Cartwright by email

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