Commentary on Sections Structure of Chapters Part 5: Chapter 1: Introduction Section 577: Territorial scope of Part 5 charges
2252.This section provides that income within Part 5 of this Act is only charged to tax if it is from a source in the United Kingdom or, if from a source outside the United Kingdom, it arises to a UK resident.
2253.It is based on section 18(1) of ICTA.
2254.The comments made in the commentary on section 368 of this Act on the absence of a charge to tax on income from outside the United Kingdom arising to non-residents apply here also. See in particular the specific comments on subsections (1), (2) and (3) of that section, the use of the term “source” and how it is proposed to include within that section income without a source.
2255.Subsection (4) serves to exclude, for example, section 587 (charge to tax on income from sales of patent rights) from the scope of this rule since that section has its own rules on territorial scope.