A: According to S18A CTA 2010, a non-resident company is generally subject to Corporation Tax at 25%. This rule is overridden when the UK has a double tax agreement with a country that includes a non-discrimination clause. If the non-discrimination clause applies, foreign companies are subject to the same rules as UK companies, allowing them to benefit from the small profits rate and marginal relief.
HMRC mentions this in their corporation tax manual at CTM03905:
Additionally, HMRC provides a list of countries it considers to have an appropriate non-discrimination article, as of April 1, 2024:
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