Corporation Tax Act 2010 section 1152

Investment managers: disregard of certain chargeable profits

Section 1152 deals with situations where a UK-based investment manager acts on behalf of a non-UK resident company and is treated as that company's permanent establishment in the UK, setting out when certain investment profits can be excluded from the profits attributed to that permanent establishment.

• Where an investment manager is treated as a permanent establishment of a non-UK resident company, certain chargeable profits from investment transactions may be disregarded when calculating the profits attributable to that permanent establishment.
• Under Case 1, profits are fully disregarded if all the independent investment manager conditions are met for the relevant investment transaction.
• Under Case 2, profits are disregarded where all the independent investment manager conditions except Condition D (the 20% rule in section 1146(6)) are met, but only to the extent that those profits do not represent relevant disregarded income to which the investment manager or a connected person is or was beneficially entitled.
• The terms "relevant disregarded income" and "beneficial entitlement" take their meanings from section 1148.