The government is exploring taxing certain non-resident companies under corporation tax. Philip Spencer and Robin Hutton (BDO) consider the possible implications.
On 20 March HM Treasury and HMRC published a consultation document which sets out proposals to bring non-UK resident companies within the charge to corporation tax in respect of their UK real estate investment activity and requesting views on the proposed changes. This article examines the proposals and the consequential issues.
What is the current position?
A company which is not resident in the UK for tax purposes has generally been outside the scope of UK tax except in relation to the following scenarios:
If it trades in the UK through a permanent establishment (PE) – which is most typically a place of business but can also include a construction site or even an employee working here – then...
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The government is exploring taxing certain non-resident companies under corporation tax. Philip Spencer and Robin Hutton (BDO) consider the possible implications.
On 20 March HM Treasury and HMRC published a consultation document which sets out proposals to bring non-UK resident companies within the charge to corporation tax in respect of their UK real estate investment activity and requesting views on the proposed changes. This article examines the proposals and the consequential issues.
What is the current position?
A company which is not resident in the UK for tax purposes has generally been outside the scope of UK tax except in relation to the following scenarios:
If it trades in the UK through a permanent establishment (PE) – which is most typically a place of business but can also include a construction site or even an employee working here – then...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
