Commentary on Sections Overview Overview
2368.This Chapter brings together the provisions of FA 2003 limiting the liability to income tax of non‑UK resident companies (liable otherwise than as trustees) and those of FA 1995 limiting such liability of all other non‑UK residents (including companies liable as trustees).
2369.This Chapter is based on:
	section 128 of FA 1995 which limits the liability to income tax of non‑UK residents, except the liability of non‑UK resident companies liable otherwise than as trustees;
	section 127 of FA 1995 so far as it supplements section 128 of that Act;
	section 151 of FA 2003 which limits the liability to income tax of non‑UK resident companies liable otherwise than as trustees; and
	Schedule 26 to FA 2003 so far as it supplements section 151(2)(c) of that Act.
2370.So far as they respectively supplement section 128 of FA 1995 and section 151(2)(c) of FA 2003, section 127 of FA 1995 and Schedule 26 to FA 2003 are in many respects substantially the same. Those provisions have, as far as possible, been combined in this Chapter.
2371.Section 127 of FA 1995 continues in force for the purpose of supplementing section 126 of that Act (UK representatives of non-residents) and Schedule 26 to FA 2003 continues in force for the purpose of supplementing section 148(3) of that Act (meaning of “permanent establishment”).