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HMRC internal manual

Double Taxation Relief Manual

Income arising in the United Kingdom: Trading and professional income: Enterprises trading in the


A non-resident person is within the charge to Income Tax on the profits from a trade carried on within the United Kingdom (ICTA88/S18 (i)(a)(iii) ).

A non-resident company (for the meaning of `company’ see CT1) which carries on a trade in the United Kingdom through a branch or agency is liable to Corporation Tax and taken out of the charge to Income Tax on the trading profits and other income of that branch or agency. For a non-resident company ICTA88/S11 is the charging section for Corporation Tax (see CT3350 onwards).