When considering whether a non-resident who is a resident of
a country with which there is no double taxation agreement is
liable to United Kingdom tax on the profits of any trade or
profession, it is only necessary to determine whether he is
carrying on a trade or profession within the United Kingdom and,
for Corporation Tax purposes, whether the trade is carried on
through a branch or agency (see DT1700). There is no reference in
the Taxes Acts to a permanent establishment.
The taxable profits of the trade are those which arise from
the trading transactions in the United Kingdom and, for Corporation
Tax, those which arise from activities in the United Kingdom and
abroad attributable to the branch or agency in the United Kingdom
(see CT3350).
In determining the expenses allowable in arriving at the net
profits, the rules in DT1728 (expenses) are generally followed.
