Corporation Tax Act 2010 section 969

Introduction to Chapter

Section 969 introduces the rules governing how corporation tax is assessed, collected and recovered from non-UK resident companies that operate in the United Kingdom through a permanent establishment, and defines the role and status of that establishment as a UK representative.

  • This Chapter covers all corporation tax rules relating to the assessment, collection and recovery of tax (and interest on tax) as they apply to non-UK resident companies and their UK representatives.
  • A permanent establishment in the UK through which a non-UK resident company trades is treated as that company's UK representative for the chargeable profits attributable to the establishment.
  • The permanent establishment continues to act as UK representative for those profits even after it ceases to be a permanent establishment through which the non-UK resident company trades.
  • The permanent establishment is treated as a distinct and separate person from the non-UK resident company, ensuring HMRC can assess and collect tax directly from it.

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