UK company residence

A company that is tax resident in the United Kingdom (UK) is generally subject to UK corporation tax on its worldwide profits unless it has made a valid foreign branch exemption election under which the profits of its non-UK permanent establishments (PEs) are, subject to exceptions, exempt from UK corporation tax.

Even if a company is not UK tax resident, it can still be subject to UK corporation tax in certain circumstances, including:

1. •

   (for disposals of UK land since 5 July 2016) in respect of profits from a trade of dealing in or developing UK land (for more information, see Practice Note: Profits from trading in and developing UK land (transactions in UK land))

2. •

   if it carries on a trade (other than a trade of dealing in or developing UK land) in the UK through a PE, in which case it is subject to UK corporation tax in respect of the profits attributable to its UK PE (for more information, see Practice Notes: What is a UK permanent establishment? and How is a UK permanent establishment taxed?)

3. •

   since 6 April 2019, if it