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After section 835A of ITA 2007 insert—

“Chapter 2B
UK Representative of Non-UK Resident

Introduction

835C Overview of Chapter

(1)     This Chapter provides for a branch or agency to be treated as the UK representative of a non-UK resident in respect of certain amounts chargeable to income tax.

(2)     For obligations and liabilities in relation to income tax imposed on a branch or agency which under this Chapter is treated as the UK representative of a non-UK resident, see Chapter 2C.”

After section 835C insert—

“835D Income tax chargeable on company's income: application

This Chapter does not apply in relation to income tax chargeable on income of a company otherwise than as a trustee.”

After section 835D insert—

“Branches and agencies

835E Branch or agency treated as UK representative

(1)     This section applies if a non-UK resident carries on (alone or in partnership) any trade, profession or vocation through a branch or agency in the United Kingdom.

(2)     The branch or agency is the UK representative of the non-UK resident in relation to—