First principles

As noted at ¶200-200, income tax is charged, in relation to business profits, on ‘the full amount of the profits of the tax year’ (s. 7(1)). The profits of a trade, profession or vocation are charged to income tax by virtue of ITTOIA 2005, s. 5. The charge to tax under ITTOIA 2005, Pt. 2 applies to those resident in the UK and to those who are not resident in the UK (s. 3(4)), but non-UK residents are in some circumstances charged to tax only on income arising in the UK. See ¶200-150 for more detail of the territorial scope of the charge.

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