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HMRC internal manual

International Manual

Company residence: why is company residence important?

Residence is important because it determines the scope of the charge to corporation tax (CTA09/S5)

A company which is resident in the UK is normally subject to corporation tax on the whole of its chargeable profits on a worldwide basis (subject to relief for double taxation).

A company which is not resident in the UK is only liable to corporation tax if it carries on a trade in the UK through a permanent establishment. A non-resident company may also be liable to UK income tax on non-trading income.