Point in time view as at 26/05/2015.
Taxation of Chargeable Gains Act 1992, Section 271C is up to date with all changes known to be in force on or before 07 March 2025. There are changes that may be brought into force at a future date. Changes that have been made appear in the content and are referenced with annotations.
(1)Subsection (2) applies if a trade or profession carried on by a non-UK resident through a branch or agency in the United Kingdom is carried on by the non-UK resident in partnership.
(2)The trade or profession carried on through the branch or agency is, for the purposes of section 271B and Chapter 2, to be treated as including the notional trade or profession.
(3)Subsection (4) applies (in addition to subsection (2) if that subsection also applies) if—
(a)a trade or profession carried on by a non-UK resident in the United Kingdom is carried on by the non-UK resident in partnership, and
(b)any member of the partnership is resident in the United Kingdom.
(4)The notional trade or profession is, for the purposes of section 271B and Chapter 2, to be treated as being a trade carried on in the United Kingdom through the partnership as such.
(5)In this section “the notional trade or profession” means the notional trade from which the non-UK resident's share in the partnership's profits or losses is treated for the purposes of section 852 of ITTOIA 2005 as deriving.]
Textual Amendments
F1Pt. 7A inserted (with effect in accordance with s. 381(1) of the amending Act) by Taxation (International and Other Provisions) Act 2010 (c. 8), s. 381(1), Sch. 6 Pt. 2 (with Sch. 9 paras. 1-9, 22)
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