Carrying on a trade in the UK

Commentary – Tax Reporter ¶764-280
Case Law – Firestone Tyre & Rubber Co., Ltd. (as agents for Firestone Tire & Rubber Co. of Akron, Ohio, U.S.A.) v. Lewellin (H.M. Inspector of Taxes) Lewellin (H.M. Inspector of Taxes) v. Firestone Tyre & Rubber Co., Ltd.

Chargeable gains

Assets ceasing to be chargeable

Commentary – Tax Reporter ¶592-550

Attribution to UK-resident participators

Commentary – Tax Reporter ¶592-900

Generally

Commentary – Tax Reporter ¶591-550 ; Tax Reporter ¶753-250

Corporation tax liability

Commentary – Tax Reporter ¶764-400

Foreign possessions or investments

Commentary – Tax Reporter ¶764-400

Generally

Commentary – Tax Reporter ¶764-260 ; Tax Reporter ¶764-400
Case Law – (1) American Foreign Insurance Association v. Davies (H.M. Inspector of Taxes (2) American Foreign Insurance Association v. Commissioners of Inland Revenue (3) American Foreign Insurance Association v. Commissioners of Inland Revenue (4) Davies (H.M. Inspector of Taxes) v. Home Insurance Company (Limited) (5) Davies (H.M. Inspector of Taxes) v. St. Paul Fire & Marine Insurance Company (Limited)

Income tax

Commentary – Tax Reporter ¶764-420
HMRC Guidance – CTM34220

Interest and royalty payments

Commentary – Tax Reporter ¶103-855

Leasing mobile drilling rigs/other assets for use on UK Continental Shelf

Commentary – Tax Reporter ¶764-400

Oil taxation

Commentary – Tax Reporter ¶798-525

Permanent establishment, meaning

Commentary – Tax Reporter ¶592-500 ; Tax Reporter ¶764-260
Case Law – (1) American Foreign Insurance Association v. Davies (H.M. Inspector of Taxes (2) American Foreign Insurance Association v. Commissioners of Inland Revenue (3) American Foreign Insurance Association v. Commissioners of Inland Revenue (4) Davies (H.M. Inspector of Taxes) v. Home Insurance Company (Limited) (5) Davies (H.M. Inspector of Taxes) v. St. Paul Fire & Marine Insurance Company (Limited) ; Puddu v Doleman (HMIT)

Relevant UK taxes

Commentary – Tax Reporter ¶700-100

Residence

Commentary – Tax Reporter ¶764-260
Case Law – (1) American Foreign Insurance Association v. Davies (H.M. Inspector of Taxes (2) American Foreign Insurance Association v. Commissioners of Inland Revenue (3) American Foreign Insurance Association v. Commissioners of Inland Revenue (4) Davies (H.M. Inspector of Taxes) v. Home Insurance Company (Limited) (5) Davies (H.M. Inspector of Taxes) v. St. Paul Fire & Marine Insurance Company (Limited)

UK representatives

Commentary – Tax Reporter ¶764-540–Tax Reporter ¶764-600