The assumed United Kingdom residence of a foreign company will not affect the computation of actual UK tax liability. For example, where the company carries on a trade in the UK through a permanent establishment, the profits of that trade chargeable to Corporation Tax are computed in the normal way in accordance with CTA09/Part 2, ICTA88/SCH24/PARA1(5)).

If the company sells UK patent rights for a capital sum, the operation of CTA09/S912), which in these circumstances requires a non-resident person to pay tax on the sum received, is not affected by the provisions of ICTA88/SCH24.

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