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HMRC internal manual

International Manual

HM Revenue & Customs
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Non-residents trading in the UK: domestic charging provisions: Income Tax charge


The Income Tax charging provisions, so far as non-residents are concerned, remained little changed from 1842 until ITTOIA was enacted in April 2005. Until then non-resident persons (i.e. both individuals and companies, including where they have acted in any combination in partnership) exercising trades, professions or vocations within the UK were chargeable to income tax on ‘the annual profits or gains arising or accruing’ calculated in accordance with the Taxes Acts in the same way as any chargeable UK resident persons. For 2005/6 onwards the income tax charging provision for non-residents is ITTOIA05/S6(2). (See INTM263000).