»Ê¹ÚÌåÓýapp

CTA09/S8, S1259  and S1266

Where a company is chargeable in respect of a trade carried on wholly abroad, the income from the trade is computed for CT purposes applying the usual trading income rules.  »Ê¹ÚÌåÓýapp charge under CT is on the income arising in the accounting period, whether or not remitted to the UK.

Where a trade is carried on abroad by a partnership of which a company resident in the UK is a member, the provisions of CTA09/S1259 (3) apply and the taxable profits of that company are computed as if the partnership were a company resident in the UK (see CTM36500 onwards).

Where a trade is carried on wholly or partly in the UK by a partnership of which a company not resident in the UK is a member, the provisions of CTA09/S1259 (4)  and (5) (calculation of profits and losses), CTA09/S1261 (6) (accounting period of deemed company) and S1266, (treatment of UK-resident partners) apply.  »Ê¹ÚÌåÓýapp taxable profits of that company are computed as if the partnership were a company not resident in the UK (see CTM36500 onwards).

This means a partner resident abroad will be liable to CT (if a company) or IT (if an individual) on the part of the profits which arises from trading in the UK.

For guidance on non-resident companies trading in the UK see CTM34200Ìý´Ç²Ô·É²¹°ù»å²õ.