SCHEDULES
SCHEDULE 26Non-resident companies: transactions through broker, investment manager or Lloyd’s agent
2Brokers
1
In relation to a transaction carried out on behalf of a non-resident company, a broker is regarded as an agent of independent status acting in the ordinary course of his business if, and only if, the following conditions are met.
2
The conditions are—
a
that at the time of the transaction he is carrying on the business of a broker;
b
that the transaction is carried out by him in the ordinary course of that business;
c
that the remuneration he receives in respect of the transaction for the provision of the services of a broker to the non-resident company is not less than is customary for that class of business; and
d
that he does not fall to be treated as a permanent establishment of the non-resident company in relation to any other transaction carried out in the same accounting period.