Michael Thomas (Pump Court Tax Chambers) examines the new legislation in Finance Bill 2016 governing sales of UK land.
Readers will recall that HMRC announced in Budget 2016 that new legislation would be introduced to ensure that profits from a trade which involves either dealing in or developing UK land are always chargeable to UK corporation tax or income tax. In particular the key objective is to prevent non-resident companies from relying on the business profits article of a double tax treaty so that profits from trading projects in UK land escape UK tax. (For more on the background see my previous article ‘Changes to treatment of offshore developers and dealers in UK land’ Tax Journal 22 April 2016.)
The legislation is now being enacted as part of the current Finance Bill having been introduced at Committee Stage....
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Michael Thomas (Pump Court Tax Chambers) examines the new legislation in Finance Bill 2016 governing sales of UK land.
Readers will recall that HMRC announced in Budget 2016 that new legislation would be introduced to ensure that profits from a trade which involves either dealing in or developing UK land are always chargeable to UK corporation tax or income tax. In particular the key objective is to prevent non-resident companies from relying on the business profits article of a double tax treaty so that profits from trading projects in UK land escape UK tax. (For more on the background see my previous article ‘Changes to treatment of offshore developers and dealers in UK land’ Tax Journal 22 April 2016.)
The legislation is now being enacted as part of the current Finance Bill having been introduced at Committee Stage....
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:
