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HMRC internal manual

Company Taxation Manual

Residence: non-resident companies: liability to IT

A non-resident company, which does not carry on a trade in the UK through a permanent establishment/branch or agency (see INTM264090), is chargeable to IT in respect of any income arising in the UK.

Similarly, a non-resident company which does carry on a trade in the UK through a permanent establishment/branch or agency is chargeable to IT in respect of any income arising in the UK which is not within (a) or (b) of CTM34210.

IT liability is at the basic rate only.