A non-resident company, which does not carry on a trade in the
UK through a branch or agency, is chargeable to IT in respect of
any income arising in the UK.
Similarly, a non-resident company which does carry on a trade
in the UK through a branch or agency is chargeable to IT in respect
of any income arising in the UK which is not within (a) or (b) of
CTM34210.
IT liability is at the basic rate only.
A non-resident company is liable on chargeable gains only to
the extent indicated in (c) of CTM34210. Accordingly, the gains are
charged to CT rather than CGT.
