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Introduction

This guidance note outlines how a non-UK company may be subject to UK tax. If the company is subject to UK tax, it may have a number of UK filing requirements (see the UK filing requirements guidance note).

A non-UK company may be directly subject to UK tax if:

1. •

   it has a permanent establishment in the UK (see the Permanent establishment guidance note)

2. •

   it is treated as resident in the UK because it is centrally managed and controlled in the UK (see the Residence of companies guidance note)

3. •

   it has UK income (for example, interest or royalty income) which is subject to UK income tax (depending on the type of income, this liability may be (at least partly) collected by the payer)

4. •

   it is within the regime for offshore receipts in respect of intangible property (see the Offshore receipts in respect of intangible property (ORIP) guidance note)

5. •

   it has UK rental income which is subject to UK withholding tax or UK corporation tax (see the Non-resident landlords scheme (NRLS) and Non-resident