Jurisdiction(s):
United Kingdom

Related legal acts

Key definition

Investment Manager Exemption definition

What does Investment Manager Exemption mean? A UK statutory safe harbour that allows a non‑UK fund (including an offshore fund) or other non‑resident investor to use a UK investment manager without the non‑resident being treated as carrying on a trade in the UK, or as having a uk permanent establishment, because of the manager’s activities. Commonly called the Investment Manager Exemption (IME), it is set out in UK tax legislation and explained in HMRC guidance. It applies if, broadly: (i) the UK manager provides investment management in the ordinary course of its business and is independent of the non‑resident; (ii) the manager is remunerated on...

Hedge funds and UK tax: trading, permanent establishments and the investment manager exemption—conditions, investment transactions, 20% rule and treaty protection

Published by a LexisNexis Tax expert

Practice notes

FORTHCOMING CHANGE relating to UK Permanent establishments:

Following a prior 2023 consultation, on 28 April 2025 the government opened a technical consultation on draft legislation overhauling the UK permanent establishment (PE) regime to:

(i) bring domestic profit attribution rules for PEs into line with the latest OECD materials and the interpretation of the ‘separate enterprise principle’,
(ii) refresh the domestic meaning of a dependent agent PE in accordance with the 2017 OECD Model Tax Convention,
(iii) revise the reach of the Investment Manager Exemption,
(iv) harmonise the domestic treatment of gains linked to PEs with the 2017 OECD Model Tax Convention, and
(v) make knock-on changes so PE concepts are applied consistently across UK tax law.

Draft legislation was published for technical comment as part of this exercise. The draft rules do not change the content or operation of any of the UK’s double tax treaties. A policy paper was issued alongside the consultation. That paper notes the earliest start date for these measures ‘will be from 1 January 2026’. The consultation period runs until 7 July 2025. See News Analyses: Tax update spring 2025—Tax analysis—Corporation tax and international and TAMD 2023—consultation on reform of permanent establishment rules. A hedge...

To view the latest version of this document and thousands of others like it, sign-in with LexisNexis or register for a free trial.

Web page updated on 21/05/2026

Popular documents

Using the Judicial College Guidelines to assess general damages in personal injury claims

When evaluating a general damages claim, the practitioner ought initially to refer to the Judicial College Guidelines (JCG)...

Tomlin orders in England and Wales: CPR guidance on drafting, confidentiality, approval, variation, enforcement, limitation, CCA issues, court-specific requirements, sample wording and precedents

This Practice Note This Practice Note reviews mechanisms used in settling litigation. A Tomlin order consists of a consent order paired with a schedule. It operates to stay proceedings on terms that have been agreed. The provisions contained in the schedule may remain confidential. This Practice Note describes the scope of confidentiality attaching to the schedule and sets out how it differs from a standard consent order. Sample wording for a Tomlin order is included, alongside links to precedents, as well as guidance on court approval. It also addresses varying, setting aside and enforcing a Tomlin order, including the considerations the court will take into account when handling applications for each. Further guidance is provided on interpreting and applying the relevant provisions of the CPR; however, some courts and divisions impose very specific requirements for both drafting and approval, and for approaching the schedule and confidentiality issues. Accordingly, you must consider the particular rules and court guide provisions in the forum where your claim is proceeding when drawing up the Tomlin order...

Precedent: Deed of Surrender of Lease with Optional Premium, Settlement and Release, Landlord, Mortgagee and Guarantor Consents, Reimbursement and HM Land Registry Provisions (England and Wales)

Date [ date ] Parties [ name of Landlord ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Landlord) [ name of Tenant ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Tenant) [ [ name of Guarantor ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Guarantor) ] [ [ name of Mortgagee ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Mortgagee) ] Definitions Within this Deed, the terms below shall be interpreted as follows: [ Annual Rent • the annual sum reserved under the Lease; ] [ Insurance Rent • the Tenant’s share of the Landlord’s costs of insuring the Property (as set out in the Lease); ] Lease • the lease of the Property dated [ date ], entered into between (1) [ the Landlord OR [ name ...

Precedent Statutory Declaration: Standard Wording under the Statutory Declarations Act 1835

I, [ name ], of [ address ], solemnly and sincerely state that: [ Matters to be verified, set out in numbered paragraphs ] I make this solemn statement in good conscience, believing it to be true, and pursuant to the provisions of the Statutory Declarations Act 1835. DECLARED at [ details ] this [ day ] day of [ month and year ] Before me ................................................................................ [ signature of the person before whom the declaration is made ] A [ commissioner for oaths OR [ solicitor OR [ insert other qualification ] ] authorised to administer oaths ]...