Income Tax Act 2007 section 1015

Territorial scope of charges under certain provisions to which section 1016 applies

Section 1015 sets out the territorial rules for charging income tax on amounts falling under specific provisions listed in Parts 2 and 3 of the table in section 1016 (that is, provisions outside ITTOIA 2005), distinguishing between the tax treatment of UK residents and non-UK residents.

• UK residents are chargeable to income tax on relevant amounts whether or not those amounts come from a UK source
• Non-UK residents are only chargeable to income tax on relevant amounts if those amounts come from a UK source
• Where an amount does not have an identifiable source, it is treated as having a UK source if it has a comparable connection to the United Kingdom
• These rules are overridden by any express or implied contrary provision elsewhere in the Income Tax Acts