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A non-UK company may be subject to UK tax either directly or indirectly. If the company is subject to UK tax, it may have a number of UK filing requirements (see the UK filing requirements guidance note).

Therefore, when setting up in the UK a company should consider whether it should set up a branch (or permanent establishment) in the UK or whether it should incorporate a UK subsidiary. The various considerations relating to this decision are discussed in the Setting up in the UK ― branch or subsidiary guidance note.

For information on the taxation of profits of overseas subsidiaries and UK permanent establishments of overseas companies, see the UK taxation of profits of overseas companies guidance note.

For a detailed discussion of some of the tax issues facing a foreign company proposing to do business in the UK other than through a UK establishment, see ‘UK tax pitfalls of the foreign company’ by Laura Hoyland and Elizabeth Emerson in Tax Journal, Issue 1489, 8 (29 May 2020).