SolvedINTM263020 | Non-residents trading in the UK: whether trading
From HM Revenue & Customs · International Manual
Mere purchase of goods does not amount to trading
The isolated activity of buying goods in the UK does not necessarily amount to trading in the UK. This principle was settled in the 1860 case of Sulley v Attorney General [2TC149]. A New York firm purchased goods in England for sale in America. It had an office here where the English resident partner saw to the purchasing and shipping of the goods. The Court of Exchequer (a Court of Appeal) found that `The profits of the firm in America do not accrue in respect of any trade carried on in this country, but in respect of the trade carried on in New York, where the main business is conducted’. Most other countries take the same view as the UK about the mere purchase of goods not usually amounting to trading.