Commentary

E1.503 Territorial scope of ITTOIA 2005, Pt 5

Personal and employment tax

E1.503 Territorial scope of ITTOIA 2005, Pt 5

E1.503 Territorial scope of ITTOIA 2005, Pt 5

Subject to any express provision to the contrary in any provision of the Income Tax Acts (including ITTOIA 2005, ss 574–689 (Pt 5)):

  1.  

    •     income under Pt 5 arising to a UK resident is chargeable to tax irrespective of the place of its source

  2.  

    •     income under Pt 5 arising to a non-UK resident, or to a UK resident in the overseas part of a split tax year, is only chargeable to tax if its source is in the UK1

Where an amount charged to tax as income does not have a source,

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