Commentary

D4.117 Non-resident companies liable to corporation tax

Corporate tax
Corporate tax | Commentary

D4.117 Non-resident companies liable to corporation tax

Corporate tax | Commentary

D4.117 Non-resident companies liable to corporation tax

The rules described in this article will not apply if different rules are included in the relevant double taxation agreement; in such a case the rules in the agreement take precedence.

A non-resident company is liable to corporation tax on profits which are attributable to the following1:

  1.  

    •     a trade of dealing in or developing UK land (B5.255)

  2.  

    •     any other trade carried on through a permanent establishment in the UK (see D4.116)

  3.  

    •     a UK property business, or

  4.  

    •     any other UK sourced property income

Such a company is chargeable to corporation tax

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