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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.

Whilst a non-resident company is chargeable to corporation tax on profits arising from a trade of dealing in or developing UK land (B5.233) or any other trade carried on through a permanent establishment in the UK¹, it is instead subject to income tax on any other income arising within the UK which is not chargeable to corporation tax².

If the company is trading in the UK, but not through a UK PE, the UK's domestic law imposes an income tax charge on the profits of the UK trade. However, if the company's home state has a double tax treaty with the UK, this charge is likely to be removed.

If the company is not trading in the UK, but has other (non-trading) income from or referable to the UK, it may have