Related Commentary  Related HMRC Manuals

643(1)  A person is–

(a)an excluded transferor in relation to a transfer by the person, and

(b)an excluded transferee in relation to a transfer to the person,

if the person is non-UK resident throughout the tax year in which the transfer occurs.

643(2)  In the case of a person who is carrying on a trade in the United Kingdom through a branch or agency during any part of that year (“a UK branch trader”), subsection (1) is subject to subsections (3) and (4).

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