A non-UK resident partner was chargeable to income tax on their share of partnership profits derived from UK trading activities with non-UK customers. 

The appellant, a British national, was a Swiss resident during the relevant tax years. He was a partner in three film partnerships (C, R, and CFSL), which carried on a trade from premises in the UK. C carried on a trade of developing commercial film opportunities through a combination of sale and leaseback transactions and film development projects from its registered office in London. CFSL carried on a trade of acquiring and managing a portfolio of qualifying British films from an office in London. R carried on a trade of acquiring and managing a portfolio of qualifying British films from its registered office in Harrow.  

The trades of all three partnerships were carried on wholly in the UK. The revenue from each of the films (whether received from lessees in the UK or abroad) was part