The charge to Corporation Tax

CTA09/S5(2), S19(1) charges Corporation Tax on non-resident companies trading in the UK through a permanent establishment (previously branch or agency). Where a company trades in the UK, other than through a permanent establishment (see INTM264050), there can be no charge to Corporation Tax. In those unusual circumstances the charge to income tax under ITTOIA05/S6(2) continues to apply. An example that would fit this situation might be a non-resident company with a peripatetic ‘door to door’ sales operation where the activities were briefly carried out at a succession of customer's premises, or a one-off sale.

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