Income arising to a UK resident is chargeable to tax under this Part whether or not it is from a source in the United Kingdom.

Income arising to a non-UK resident is chargeable to tax under this Part only if it is from a source in the United Kingdom.

References in this section to income which is from a source in the United Kingdom include, in the case of any income which does not have a source, references to income which has a comparable connection to the United Kingdom.

This section is subject to any express or implied provision to the contrary in this Part (or elsewhere in the Income Tax Acts).