Commentary

D9.436 Non-residents

Corporate tax
Corporate tax | Commentary

D9.436 Non-residents

Corporate tax | Commentary

D9.436 Non-residents

A person who is not resident in the United Kingdom throughout the tax year in which he or she acquires or disposes of the securities is excluded from the accrued income scheme in respect of that transaction1. This exclusion does not apply to the other party to the transaction.

The exclusion does not apply where the person is trading in the United Kingdom through a branch or agency during any part of the tax year and the securities were acquired, used or held for the purposes of the branch and were situated in the United Kingdom2.

FOTRA

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