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Part 2U.K.Trading income

Chapter 2U.K.Income taxed as trade profits

Charge to tax on trade profitsU.K.

6Territorial scope of charge to taxU.K.

(1)Profits of a trade arising to a UK resident are chargeable to tax under this Chapter wherever the trade is carried on.

[F1(1A)Profits of a trade of dealing in or developing UK land arising to a non-UK resident are chargeable to tax under this Chapter wherever the trade is carried on.]

(2)Profits of a trade [F2other than a trade of dealing in or developing UK land] arising to a non-UK resident are chargeable to tax under this Chapter only if they arise—

(a)from a trade carried on wholly in the United Kingdom, or

(b)in the case of a trade carried on partly in the United Kingdom and partly elsewhere, from the part of the trade carried on in the United Kingdom.

[F3(2A)If the tax year is a split year as respects a UK resident individual, this section has effect as if, for the overseas part of that year, the individual were non-UK resident.]

(3)This section applies to professions and vocations as it applies to trades.

Textual Amendments

F1S. 6(1A) inserted (with effect in accordance with s. 82 of the amending Act) by Finance Act 2016 (c. 24), s. 78(1)(a) (and also with effect in accordance with Finance (No. 2) Act 2017 (c. 32), s. 39(1)(2))

F2Words in s. 6(2) inserted (with effect in accordance with s. 82 of the amending Act) by Finance Act 2016 (c. 24), s. 78(1)(b) (and also with effect in accordance with Finance (No. 2) Act 2017 (c. 32), s. 39(1)(2))

F3S. 6(2A) inserted (with effect in accordance with Sch. 45 para. 153(2) of the amending Act) by Finance Act 2013 (c. 29), Sch. 45 para. 75