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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Non-residents: UK income: Residents of non- agreement countries


When considering whether a non-resident who is a resident of a country with which there is no double taxation agreement is liable to United Kingdom tax on the profits of any trade or profession, it is only necessary to determine whether he is carrying on a trade or profession within the United Kingdom and, for Corporation Tax purposes, whether the trade is carried on through a branch or agency (see DT1700). There is no reference in the Taxes Acts to a permanent establishment.

The taxable profits of the trade are those which arise from the trading transactions in the United Kingdom and, for Corporation Tax, those which arise from activities in the United Kingdom and abroad attributable to the branch or agency in the United Kingdom (seeCT3350).

In determining the expenses allowable in arriving at the net profits, the rules in DT1728 (expenses) are generally followed.