[INTM262300] Non-residents trading in the UK: Is there a charge under domestic legislation: Domestic charging provisions
Once it has been established that there is trading in the UK the next step is to identify the particular charging provisions that are applicable (see the flow chart at INTM262100).
The territorial restriction has been removed for UK land transactions. With effect from 5 July 2016 CTA09/S5 and ITTOIA05/S6 have been amended : non-resident companies, and non-resident non-corporates are now within the charge to corporation tax or income tax (as appropriate) on the full profit from carrying on a trade of dealing in or developing UK land.
It is not necessary for them to be trading through a permanent establishment in the UK or for them to be UK resident for the charge to apply.