188体育

Meaning of 鈥榩lace of abode鈥�

ITA07/S874 (1)(d) requires deduction of tax from a payment to a person 鈥榳hose usual place of abode is outside the United Kingdom鈥�. This phrase is distinguishable from the concept of 鈥榬esidence鈥�, and is to be interpreted as follows.

Individuals

An individual鈥檚 usual place of abode is outside the UK if he or she usually lives abroad, unless that arrangement is temporary.

Companies

A company whose main place of business is outside the UK will usually have its usual place of abode abroad unless it is resident here.

But a non-UK resident company that has a UK permanent establishment that is within the charge to corporation tax does not have a usual place of abode abroad.

Trustees

Trustees, including personal representatives, have a usual place of abode abroad if each trustee, considered as an individual or a company as the case may be, has a usual place of abode there. So if one trustee does not have a usual place of abode abroad, neither does the trust.