Commentary on Sections Overview Overview Section 5: Income tax and companies
32.This section provides that income of companies that is liable to corporation tax is not charged to income tax. It is based on sections 6(2) and 11(1) of ICTA.
33.In brief, a company’s income (other than income arising to it in a fiduciary or representative capacity) is within the charge to corporation tax if:
	the company is UK resident; or
	the company is non‑UK resident and:(a)the income is trading income arising through or from a permanent establishment in the United Kingdom of the company; or(b)the income arises from property or rights used by, or held by or for, the permanent establishment.
See the commentary on section 835 in relation to the residence of companies.