If a company is not resident in the UK CTA09/S5 (2) says that it is not within the charge to Corporation Tax unless it carries on a trade in the UK through a permanent establishment.
Until 2003 the legislation referred to a UK branch or agency, the term that is still used for persons other than companies, see CG25500+. The term ‘permanent establishment’ is used in double tax treaties and is defined at CTA10/S1141. For further guidance see INTM260000 onwards.
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