Income Tax Act 2007 section 815

Limit on liability to income tax of non-UK resident companies

Section 815 sets a cap on the total income tax that a non-UK resident company (not acting as a trustee) can be required to pay for any given tax year.

• The section applies only to non-UK resident companies liable to income tax in their own right, not as trustees.
• The company's total income tax liability for a tax year is capped at the sum of two amounts, referred to as Amount A and Amount B.
• Amount A covers income tax already deducted or treated as deducted from, or paid in respect of, the company's "disregarded company income" for the year.
• Amount B is the income tax the company would otherwise owe for the year if its disregarded company income were completely ignored.