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HMRC internal manual

Double Taxation Relief Manual

Non-residents: UK income: Branch or agency

Branch or agency is defined in the Corporation Tax Acts interpretation ICTA88/S834 (1) - `branch or agency’ means any factorship, agency, receivership, branch or management. This mirrors the interpretation for the purpose of the machinery provisions in TMA70/S118. IM170 onwards contains instructions on agency and `trading in’ the United Kingdom. The presence of a principal (in the case of a sole trader or partnership) or of employees on a more or less regular basis is likely to be an essential ingredient of a branch (although employees may also be agents). Refer any cases where there is doubt as to whether a non-resident is trading in the United Kingdom through a branch or agency to International Division, Business Tax Group.