Helen Adams (BDO) takes a closer look at the new powers to investigate the UK tax paid by offshore developers of UK land and buildings.
HMRC launched the Offshore Property Developers Task Force (OPDTF) in 2016 to tackle perceived tax avoidance involving offshore developers of UK land.
Prior to FA 2016 s 76 some offshore property development companies considered they were non-UK resident without a UK permanent establishment so no UK corporation tax was due on their profits. Companies incorporated in jurisdictions such as Jersey and Guernsey also considered that treaty relief was available so that no UK income tax was due on the development’s profits either. While the new legislation alters the position for development profits from 5 July 2016 (subject to anti-forestalling rules effective from 16 March 2016) by making profits automatically assessable to corporation tax regardless of where the developer is located it...
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Helen Adams (BDO) takes a closer look at the new powers to investigate the UK tax paid by offshore developers of UK land and buildings.
HMRC launched the Offshore Property Developers Task Force (OPDTF) in 2016 to tackle perceived tax avoidance involving offshore developers of UK land.
Prior to FA 2016 s 76 some offshore property development companies considered they were non-UK resident without a UK permanent establishment so no UK corporation tax was due on their profits. Companies incorporated in jurisdictions such as Jersey and Guernsey also considered that treaty relief was available so that no UK income tax was due on the development’s profits either. While the new legislation alters the position for development profits from 5 July 2016 (subject to anti-forestalling rules effective from 16 March 2016) by making profits automatically assessable to corporation tax regardless of where the developer is located it...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
