Section 271J Meaning of “non-UK resident” and “independent agent”F1
In this Chapter “non-UK resident” means a person who is not resident in the United Kingdom.
In this Chapter “independent agent”, in relation to a non-UK resident (“X”), means a person who is the UK representative of X in respect of any agency in which the person is acting on behalf of X in an independent capacity.
For this purpose a person does not act in an independent capacity on behalf of X unless 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.
Annotations
Textual amendments
- F1
Pt. 7A inserted (with effect in accordance with s. 381(1) of the amending Act) by Taxation (International and Other Provisions) Act 2010 (c. 8), s. 381(1), Sch. 6 Pt. 2 (with Sch. 9 paras. 1-9, 22)