Section 3 | Exclusion of charge to income tax

(1)The provisions of the Income Tax Acts relating to the charge to income tax do not apply to income of a company if—

(a)the company is UK resident, or

(b)the company is not UK resident and it is chargeable to corporation tax in respect of the income, or would be so chargeable but is not as a result of—

an exemption, orthe application of sections 1142 to 1144 of CTA 2010 (circumstances in which a company is not regarded as having a permanent establishment).

(2)Subsection (1) does not apply to income accruing to a company in a fiduciary or representative capacity.