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Home / Simons-Taxes /Personal and employment tax /Part E1 Income tax /Division E1.5 Miscellaneous and exempt income /Miscellaneous and exempt income—scope of the division / E1.503 Territorial scope of ITTOIA 2005, Pt 5
Commentary

E1.503 Territorial scope of ITTOIA 2005, Pt 5


Personal and employment tax

Subject to any express provision to the contrary in any provision of the Income Tax Acts (including ITTOIA 2005, ss 574–689A (Pt 5)):

  1. Ìý

    •ÌýÌýÌýÌý income under Pt 5 arising to a UK resident is chargeable to tax irrespective of the place of its source

  2. Ìý

    •ÌýÌýÌýÌý income under Pt 5 arising to a non-UK resident, or to a UK resident in the overseas part of a split tax year, is only chargeable to tax if its source is in the UK1

Where an amount charged to tax as income does not have a source, it is deemed to have a source in the UK, if its connection to the UK is comparable to

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