Taxation (International and Other Provisions) Act 2010 (c. 8)

SCHEDULES

SCHEDULE 6 U.K. UK Representatives of non-UK residents

Part 1 U.K. New Chapters 2B and 2C of Part 14 of ITA 2007

5 U.K. After section 835F insert—

“Persons who are not UK representatives U.K.

835G Agents

(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.”