Section 271C: Trade or profession carried on in partnership

Taxation of Chargeable Gains Act 1992 · 1992 c. 12View on legislation.gov.uk

Part 7A: UK representatives of non-UK residents — Chapter 1: Treatment of branch or agency as UK representative of non-UK resident

Subsection (2) applies if a trade or profession carried on by a non-UK resident through a branch or agency in the United Kingdom is carried on by the non-UK resident in partnership.

The trade or profession carried on through the branch or agency is, for the purposes of section 271B and Chapter 2, to be treated as including the notional trade or profession.

Subsection (4) applies (in addition to subsection (2) if that subsection also applies) if—

a trade or profession carried on by a non-UK resident in the United Kingdom is carried on by the non-UK resident in partnership, and
any member of the partnership is resident in the United Kingdom.

The notional trade or profession is, for the purposes of section 271B and Chapter 2, to be treated as being a trade carried on in the United Kingdom through the partnership as such.

In this section "the notional trade or profession" means the notional trade from which the non-UK resident's share in the partnership's profits or losses is treated for the purposes of section 852 of ITTOIA 2005 as deriving.

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Reuse reviewed 21 August 2026 under Open Government Licence v3.0.