352. Determination of profits attributable to permanent establishment.

The following provisions1 apply for the purposes of the charge to corporation tax on income if a non-UK resident company2 carries on a trade in the United Kingdom through a permanent establishment in the United Kingdom3.

The company's chargeable profits are:

  1.  

    (1)     trading income arising directly or indirectly through or from the establishment; and

  2.  

    (2)     income from property or rights used by, or held by or for, the establishment4.

In addition, a charge to corporation tax on chargeable gains may arise on the disposal of assets situated in the United Kingdom that have a relevant connection to the company's UK permanent