A person is within the charge to corporation tax if that person has a source of income which is within the charge to corporation tax. A source of income is within the charge to corporation tax if that tax is chargeable on the income arising from it, or would be so chargeable if there were any such income.

However, a company not resident in the UK is only within the charge to corporation tax if it carries on a trade in the UK through a permanent establishment (CTA 2009, s. 5(2)).

A company may come within the charge to corporation tax if it:

(1)acquires an appropriate source of income, not previously having had one; or

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