Part 2

Charge to corporation tax: basic provisions
Chapter 4

Non-UK resident companies: chargeable profits

Chargeable profits

Chargeable profits
19
1
This section applies if a non-UK resident company carries on a trade in the United Kingdom through a permanent establishment in the United Kingdom.
2
The company’s chargeable profits are its profits that are—
a
of a type mentioned in subsection (3), and
b
attributable to the permanent establishment in accordance with sections 20 to 32.
3
The types of profits referred to in subsection (2)(a) are—
a
trading income arising directly or indirectly through or from the establishment,
b
income from property or rights used by, or held by or for, the establishment, and
c
chargeable gains falling within section 10B of TCGA 1992 (non-resident company with United Kingdom permanent establishment)—
i
as a result of assets being used in or for the purposes of the trade carried on by the company through the establishment, or
ii
as a result of assets being used or held for the purposes of the establishment or being acquired for use by or for the purposes of the establishment.