Non-UK companies subject to UK tax

By Tolley in association with Robert Langston of Saffery Champness
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The following Corporation Tax guidance note by Tolley in association with Robert Langston of Saffery Champness provides comprehensive and up to date tax information covering:

  • Non-UK companies subject to UK tax
  • Introduction
  • Collection of UK tax from non-resident companies
  • Limit on UK tax liability
  • Further reading

Introduction

This guidance note outlines how a non-UK company may be subject to UK tax. If the company is subject to UK tax, it may have a number of UK filing requirements (see the UK filing requirements guidance note).

A non-UK company may be subject to UK tax if:

  • it has a permanent establishment in the UK (see the Permanent establishment guidance note)
  • it is treated as resident in the UK because it is centrally managed and controlled in the UK (see the Residence of companies guidance note)
  • it has UK interest or royalty income which is subject to UK withholding tax
  • it has UK rental income which is subject to UK withholding tax (see the Non-resident landlords guidance note)
  • it is trading in or developing UK property, even where no permanent establishment exists. See the Transactions in UK land guidance note for further details (FA 2016, ss 76–77)

A non-UK company may indirectly be subject to UK tax if:

  • its profits are attributed to a UK parent company under the controlled foreign company rules (see the Controlled foreign companies (CFCs) guidance note)
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More on UK tax for non-UK companies: