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A company that is not resident in the UK will only be subject to UK corporation tax if it carries on a trade in the UK through a permanent establishment. Where it does so, it will be subject to UK corporation tax on all profits that are attributable to the UK permanent establishment. There are exceptions to this rule for any person:

1. •

   dealing in and developing UK land ― see the Transactions in UK land guidance note for further information

2. •

   directly or indirectly disposing of UK land ― see the Disposals of UK land by non-resident companies (NRCG regime) ― overview guidance note

3. •

   that generates profits from a UK property business ― see the Non-resident landlords scheme (NRLS) guidance note

CTA 2009, s 5(2)

This guidance note outlines when an overseas company will have a permanent establishment in the UK and how to calculate the profits attributable to that permanent establishment.

The same principles may apply when determining whether a UK company has a permanent establishment in another country. In