P8. Company ceasing to be resident

Residence

 

Exclusions from income tax charge for non-resident company on non-UK income

Trading income - ITTOIA 2005, s.6

Property income - ITTOIA 2005, s.269

Savings and investment income - ITTOIA 2005, s.368

Miscellaneous income - ITTOIA 2005, s.577

Employment income - ITEPA 2003, s.15

Pension income - ITEPA 2003, s.575

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Relief for non-resident company on UK income

Income tax liability of non-resident company is limited to tax deducted at source plus tax on income that is not disregarded company income. 

Property income is not disregarded income.

Legislation: ITA 2007, s.815

HMRC manuals:

Commentary: Kessler, Chapter 50; 

See further: 

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Requirement for economic substance in certain jurisdictions

- E.g. Jersey

- High-risk IP companies presumed to fail substance test unless prove otherwise.

- Does not automatically lead to UK residence, but leads to exchange of information, penalties and potential striking off

Legislation: 

Cases: 

HMRC manuals: 

Commentary: 

See also:

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