Corporation Tax Act 2009 section 19

Chargeable profits

Section 19 defines which profits of a non-UK resident company trading in the United Kingdom through a permanent establishment are subject to corporation tax as "chargeable profits".

• A non-UK resident company trading in the UK through a permanent establishment is subject to corporation tax on profits attributable to that establishment, known as "chargeable profits"
• Chargeable profits include trading income arising through or from the establishment, and income from property or rights used by, or held by or for, the establishment
• Certain profits are excluded from chargeable profits, including profits from dealing in or developing UK land, UK property business profits, other UK property income, and profits from loan relationships or derivative contracts connected with UK property activities
• Chargeable gains are also subject to corporation tax, but only to the extent they are attributable to the permanent establishment