Income Tax (Trading and Other Income) Act 2005 section 6

Territorial scope of charge to tax

Section 6 sets out the territorial limits of the income tax charge on profits from trades, professions and vocations, distinguishing between the treatment of UK residents and non-UK residents.

• UK residents are taxable on all trading profits regardless of where in the world the trade is carried on
• Non-UK residents dealing in or developing UK land are taxable on those profits wherever the trade is carried on
• Other non-UK resident traders are only taxable on profits arising from trade carried on wholly or partly in the UK, limited to the UK portion where the trade spans multiple jurisdictions
• Where a UK resident individual has a split year, they are treated as non-UK resident for the overseas part of that year