INTM151010 - Double taxation: concept and principles
UK and foreign legislation
United Kingdom domestic legislation generally provides that
- all income which arises in the United Kingdom, whether derived by a United Kingdom resident or not, and
- income derived from abroad by a United Kingdom resident,
is chargeable to United Kingdom tax.
Examples of (a) are income from property (ICTA88/S15), income
from a trade, profession or vocation exercised within the United
Kingdom (ICTA88/S18 (1) ), income from employments ( ITEPA03/S21)
and income from exploration or exploitation activities in the
United Kingdom or in an area designated under the Continental Shelf
Act 1964 (ICTA88/S830 (5) ).
Examples of (b) are income from securities and possessions
out of the United Kingdom chargeable under Cases IV and V of
Schedule D (ICTA88/S18 (2) ) and income from employments abroad
chargeable under ITEPA03/S21.
Many foreign countries have taxation systems based on similar
principles so that income which arises in one country and flows to
the other country is taxed twice, once in the country of its origin
and again in the country in which the recipient resides.
