•is chargeable to corporation tax on all its profits, wherever arising, unless the foreign branch exemption (¶764-755) applies (CTA 2009, s. 5(1)); and

•is not chargeable to income tax (CTA 2009, s. 3(1)).

•HMRC consultation Taxing gains made by non-residents on UK immovable property.

•HMRC summary of responses to consultation Non-resident companies chargeable to income tax and non-resident CGT.

•Taxation of property businesses (¶711-000).