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5(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).

5(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), or

(b)it carries on a trade in the United Kingdom (other than a trade of dealing in or developing UK land) through a permanent establishment in the United Kingdom.

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