Company Taxation Manual

CTM34250 - Residence: non-resident companies: 바카라 사이트˜charges received바카라 사이트™: income from which income tax has been deducted

If a non-UK resident company within the charge to Corporation Tax receives what used to be called a 바카라 사이트˜charge바카라 사이트™ on income (income comprising annual payments from which Income Tax has been deducted by the payer - see CTM09005 and PIM4810), the gross payment is treated as income in its hands and is chargeable to Corporation Tax and not to Income Tax so far as it falls within the chargeable profits of the company (CTM34210). The rules governing set-off of any Income Tax borne against the Corporation Tax liability are at CTA10/S968. 바카라 사이트˜Taxed income바카라 사이트™ in this context might include, for example, patent royalties received by a manufacturing concern, or interest on the reserve fund investments of the UK branch of a foreign bank, or rental income from UK property to which the Non-resident Landlord Scheme applies..

A 바카라 사이트˜charge바카라 사이트™ received by a non-UK resident company which does not fall within the previous paragraph will, subject to the provisions of any relevant Double Taxation Agreement, be within the charge to Income Tax, so far as it arises in the UK.