{
  "url": "https://openlegislation.uk/income-tax-act-2007/section-818",
  "json_url": "https://openlegislation.uk/income-tax-act-2007/section-818.json",
  "legislation": "ukpga/2007/3",
  "legislation_title": "Income Tax Act 2007",
  "legislation_url": "https://openlegislation.uk/income-tax-act-2007",
  "path": "section/818",
  "kind": "section",
  "number": "818",
  "heading": "The independent investment manager conditions",
  "text": "(1) The independent investment manager conditions are met in relation to an investment transaction carried out on behalf of a non-UK resident by an investment manager in the United Kingdom if conditions A to E are met.\n(2) Condition A is that at the time of the transaction the investment manager is carrying on a business of providing investment management services.\n(3) Condition B is that the transaction is carried out in the ordinary course of that business.\n(4) Condition C is that, when the investment manager acts on behalf of the non-UK resident in relation to the transaction, the relationship between them, having regard to its legal, financial and commercial characteristics, is a relationship between persons carrying on independent businesses dealing with each other at arm's length.\n(5) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .\n(6) Condition E is that the remuneration which the investment manager receives in respect of the transaction for the provision of investment management services to the non-UK resident is not less than is customary for that class of business.\n(7) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .\n(8) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Words in s. 818(1) substituted (21.7.2008 with effect in accordance with Sch. 16 para. 11(3) of the amending Act) by Finance Act 2008 (c. 9), Sch. 16 para. 10(2)"
    },
    {
      "type": "F",
      "label": "F2",
      "text": "S. 818(5) omitted (for chargeable periods beginning on or after 1.1.2026) by virtue of Finance Act 2026 (c. 11), Sch. 7 paras. 23(1), 30"
    },
    {
      "type": "F",
      "label": "F3",
      "text": "S. 818(7) omitted (21.7.2008 with effect in accordance with Sch. 16 para. 11(3) of the amending Act) by virtue of Finance Act 2008 (c. 9), Sch. 16 para. 10(3)"
    },
    {
      "type": "F",
      "label": "F4",
      "text": "S. 818(8) omitted (21.7.2008 with effect in accordance with Sch. 16 para. 11(3) of the amending Act) by virtue of Finance Act 2008 (c. 9), Sch. 16 para. 10(3)"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2007/3/section/818",
    "retrieved_at": "2026-10-29T09:13:03.599581+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."
}