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HMRC internal manual

International Manual

Non-residents trading in the UK: Introduction: Introduction to the module

Introduction to the module

Source rule of UK taxation

This section of the guidance concerns non-residents with a trade, profession or vocation in the UK and details the circumstances in which, and the means by which, the UK taxes the profits arising in the UK to a non-resident. This includes individuals, companies and partnerships (where one or more partner(s) are non-resident and any of the activities of the partnership amount to trading in the UK).


Self assessment

Where non-residents are chargeable in the UK, Self Assessment (IT or CT) applies. Specialist Personal Tax (part of BAI) is the responsible HMRC office for a non-resident individual. Non-resident companies with permanent establishments in the UK are required under the Companies Act to register with Companies House. For a shortcut to the guidance booklet on the Companies House web-site see .  Companies House now offers a joint registration service whereby registration for tax purposes can be made at the same time. A notification of registration of a permanent establishment will come from Companies House to the HMRC office covering the registered office address in the UK. That office will usually be the responsible office for the non-resident company.


Other relevant guidance

Other related sections of guidance on taxation of non-residents that you may be interested in are:

  • Taxation of non-resident landlords on income from UK properties - SALF703 
  • Taxation of non-residents on income from employment in the UK - EIM35000+ 
  • Taxation of non-residents on investment income arising in the UK - SALF706 
  • Taxation of non-residents carrying out a trade in dealing or developing UK land - BIM60510
  • The differences in treatment between resident and non-resident companies - CTM34230 

Non-residents process map


In all cases where you are considering the potential chargeability of a non-resident you should consider the facts of the case in the process illustrated below. The relevant guidance for each stage of consideration is sign-posted accordingly.

Stage 1

Is there a charge under domestic legislation on the activities in question? If there is not, you need consider the case no further. [See INTM262000]. If there is, Stages 2 and 4 should be considered from the outset.

Stage 2

If the non-resident is a resident of a state with which we have a Double Taxation Agreement, does the treaty restrict the domestic charge? [See INTM264000]

Stage 3

How much are the chargeable profits that can be taxed in the UK? [See INTM267000]

Stage 4

Having established that there is a domestic charge and having taken account of the effects of the relevant treaty, how do we assess and collect any tax that is due? [See INTM268000]

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