Territorial Scope: Para. 89 and ITTOIA 2005, s. 577

ITTOIA 2005, Part 5 imposes Income Tax on miscellaneous income. Chapter 1 of Part 5 contains general provisions in relation to the charge on miscellaneous income and Chapters 2 – 8 contain the rules relating to particular categories of such income. Section 577 falls within Chapter 1 and concerns the territorial scope of the Part 5 charges. It provides that:

‘(1)Income arising to a UK resident is chargeable to tax under this Part whether or not it is from a source in the United Kingdom.

(2)Income arising to a non-UK resident is chargeable to tax under this Part only if it is from a source in the United Kingdom. ’

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