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HMRC internal manual

Capital Gains Manual

Payment of tax: UK representatives of non residents

TCGA92/S271A - S271J and CTA10/S969 - S972


  • a non-resident carries on a trade, profession or vocation in the UK through a branch or agency, see CG25500+, or
  • a non-resident company carries on a trade in the UK through a permanent establishment, see CG42100+

any liability to Capital Gains Tax, or to Corporation Tax on chargeable gains, can be collected from the UK representative of the non-resident person.

There is guidance on collection from UK representatives at INTM268000 onwards.