[INTM267030] Non-residents trading in the UK: profits of the PE: Domestic provisions on quantifying chargeable profits – Income Tax and Corporation Tax
A non-resident carrying on a trade in the UK is chargeable to UK tax on the profits arising from the UK activities. The charge could be to income tax or corporation tax. The guidance at INTM262000 covers the domestic charging provisions in more detail and this section only concerns how the chargeable profits are quantified. Although the CT charging provisions are more explicit on quantification of chargeable profits than the IT charging provisions, in either instance the overall profits and gains chargeable to UK tax in respect of the non-resident should be substantially the same in the majority of cases.