Commentary

A1.109 Territorial concepts and limitations

Administration and compliance

A1.109 Territorial concepts and limitations

A1.109 Territorial concepts and limitations

The UK means Great Britain (England, Wales and Scotland) and Northern Ireland1. Tax provisions are enacted, construed and administered with a view to producing identical effects, as far as possible, in England and Wales, Scotland and Northern Ireland2.

The territorial sea of the UK is deemed to be part of the UK for income tax, corporation tax and capital gains tax purposes3. Exploration or exploitation activities carried on in an area designated under the Continental Shelf Act 1964 s 1(7)4 and rights to assets so produced, are treated as sited in the UK5. A foreign employer, if he

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