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HMRC internal manual

Business Income Manual

Sale of income by an individual in exchange for capital: deduction of tax from payments

S944 Income Tax Act 2007

Non-residents as well as residents may be liable under the sale of income legislation but only if the occupation (see BIM100360) is carried on wholly or partly in the UK.

Where a capital amount is payable to a non-resident, HMRC may direct that Income Tax must be deducted on payment, the payer accounting to HMRC according to the ordinary procedure.