Corporation Tax

Non-UK companies subject to UK tax

Produced by Tolley
  • 05 Nov 2021 06:51

The following Corporation Tax guidance note Produced by Tolley 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
  • UK representative
  • Other group companies
  • UK rental income
  • Interest, royalties and other income
  • Limit on UK tax liability
  • Further reading

Non-UK companies subject to UK tax

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:

  1. it has a permanent establishment in the UK (see the Permanent establishment guidance note)

  2. 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)

  3. it has UK interest or royalty income which is subject to UK withholding tax

  4. it has royalty income which is subject to UK income tax

  5. it is within the regime for offshore receipts in respect of intangible property from 6 April 2019 (see the Offshore receipts in respect of intangible property guidance note)

  6. it has UK rental income which is subject to UK withholding tax or UK corporation tax from 6 April 2020 (see the Non-resident landlords scheme (NRLS) guidance note)

  7. 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

  8. it makes a direct or indirect disposal of UK land. See the Overview of the rules on disposals of interests in UK land by non-residents guidance note for further details

  9. from April 2020, a digital services tax was introduced at a rate of 2% on revenues derived from UK users in respect of certain digital businesses; for more details, see the Digital Services Tax (DST) guidance note

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

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