Persons who are not UK representatives

835GAgents

1

This section applies if a non-UK resident carries on (alone or in partnership) a business through an agent in the United Kingdom.

2

The agent is not the UK representative of the non-UK resident in relation to an amount within section 835E(2) arising to the non-UK resident from—

a

so much of the non-UK resident's business as relates to disregarded transactions, or

b

property or rights which, as a result of disregarded transactions, are used by, or held by or for, the agent on behalf of the non-UK resident.

3

“Disregarded transactions” are transactions—

a

carried out through the agent in the United Kingdom, and

b

in respect of which the agent does not act in the course of carrying on a regular agency for the non-UK resident.