[CTM34210] CTM34210 – Residence: non-resident companies: liability to CT
Under CTA09/S5 (2) a company not resident in the UK is only chargeable to Corpora tion Tax if
•it carries on a trade in the UK through a permanent establishment or branch/agency (see INTM264090 for the distinction)
•from 5 July 2016, it carries on a trade of dealing in or developing UK land (see BIM60510 onwards)
•from 6 April 2020, it carries on a UK property business or it has other UK property income.
In addition, FA19 widened the scope of TCGA92/S21A to bring gains relised by non-UK resident companies on direct and indirect disposals of UK land within the charge to CT with effect from 6 April 2019 (see CG73920 onwards).