Commentary on Sections Part 2: Charge to corporation tax: basic provisions Overview Section 14: Companies incorporated in the United Kingdom
91.This section provides that a company incorporated in the United Kingdom is resident here for corporation tax purposes and, under section 5, is within the charge to corporation tax on all its income and chargeable gains. It is based on section 66(1) of FA 1988.
92.Subsection (2) makes it clear that a company which is resident in the United Kingdom under subsection (1) is not resident in any other territory.
93.Although section 66 of FA 1988 and section 249 of FA 1994 refer to a company being “regarded as” resident it is not considered necessary to adopt that or similar wording. A company is simply resident somewhere.