Non-UK companies subject to UK tax

Produced by Tolley
Non-UK companies subject to UK tax

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

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 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

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