The Investment Management Exemption - Recent Insight from the HMRC on Proposed Tax Changes  

June 01, 2007

At a May 2007 meeting, HRMC outlined its latest thinking on the key tests that will be relevant in determining whether funds and other clients of investment managers (and investment managers themselves) will be liable for tax on trades carried out in the UK through the agency of the investment manager. Investment funds and other clients not residing in the UK for tax purposes can be liable for UK tax on trading profits when the trade is carried out in the UK through an agent, such as an investment manager. However, special rules (the so called "Investment Management Exemption") (IME)) were devised over a decade ago to provide protection from such charges when the agent is an investment manager.

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