5 Territorial scope of charge

General scheme of corporation tax

5  Territorial scope of charge

(1)     A UK resident company is [chargeable to corporation tax on income] on all its profits wherever arising [(but see Chapter 3A for an exemption from charge in respect of profits of foreign permanent establishments)].

[(2)     A non-UK resident company is [within the charge to corporation tax on income] only if—

(a)     it carries on a trade of dealing in or developing UK land (see section 5B), . . .

(b)     it carries on a trade in the United Kingdom (other than a trade of dealing in or

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