The rules described in this article will not apply if different rules are included in the relevant double taxation agreement; in such a case the rules in the agreement take precedence.
A non-resident company is liable to corporation tax on profits which are attributable to any trade carried on through a permanent establishment in the UK1. Note, non-resident companies that do not trade through a UK PE may still be liable to corporation tax, income tax or CGT on certain activities, see D4.115.
Broadly, and subject to the terms of the relevant double taxation agreement, a company has a permanent establishment in a territory
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