Introduction Overview Overview Section 1152: Investment managers: disregard of certain chargeable profits
3285.This section applies if an investment manager falls to be treated as a permanent establishment in the United Kingdom of a non-UK resident company. It is based on paragraph 5A of Schedule 26 to FA 2003.
3286.The section provides that in the two cases specified in subsection (2) some or all of the profits derived from an investment transaction carried out by the investment manager on behalf of the non-UK resident company are disregarded when attributing profits to the permanent establishment.
3287.If Case 2 applies, the disregard is only of that part of the non-UK resident company’s income from the transaction to which the investment manager and persons connected with the investment manager are not beneficially entitled (see subsection (3)).