{
  "url": "https://openlegislation.uk/finance-act-2003-schedule-26-paragraph-33-designated-transactions-regulations-2003/note",
  "json_url": "https://openlegislation.uk/finance-act-2003-schedule-26-paragraph-33-designated-transactions-regulations-2003/note.json",
  "legislation": "uksi/2003/2173",
  "legislation_title": "The Finance Act 2003, Schedule 26, Paragraph 3(3) (Designated Transactions) Regulations 2003",
  "legislation_url": "https://openlegislation.uk/finance-act-2003-schedule-26-paragraph-33-designated-transactions-regulations-2003",
  "path": "note",
  "kind": "note",
  "number": null,
  "heading": "Explanatory note",
  "text": "(This note is not part of the Regulations)\nSection 150 of the Finance Act 2003 (c. 14) imposes obligations in relation to corporation tax on the UK representative of a non-resident company. Section 148 of that Act explains the concept of permanent establishment for the purposes of the Tax Acts. Paragraph 3 of Schedule 26 sets out circumstances in which an investment manager is not to be regarded as a UK representative but as an independent agent.\nThese Regulations designate some financial swap contracts as investment transactions for the purposes of paragraph 3 of Schedule 26. The effect is to extend the scope for regarding investment managers as independent agents for the purposes of paragraph 3 of Schedule 26.\nRegulation 1 provides for the citation and commencement of the Regulations.\nRegulation 2 designates some swap contracts for the purposes of paragraph 3 of Schedule 26.",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/uksi/2003/2173/note",
    "retrieved_at": "2026-10-29T06:00:47.822485+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}