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Non-resident companies: disposals of UK land

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HMRC has updated its guidance Register a non-resident company for corporation tax to note that the exemption from the requirement for non-UK resident company landlords to notify chargeability to corporation tax, because their tax liability was fully offset by tax deducted under the non-resident landlord scheme, will cease to apply if they make a disposal in an accounting period ending on or after 6 April 2020. This follows the changes from that date bringing non-UK resident companies into corporation tax rather than income tax in relation to profits from a UK property business.

In related guidance Carry forward corporation tax losses, HMRC confirms that where a company was chargeable to income tax on its UK property business profits in the period when a property loss arose, the income tax loss will be brought forward into the corporation tax regime but can only be carried forward against its UK property profits or other UK property income and must be used in priority to any losses arising on or after 6 April 2020. Any such carry-forward is not affected by the general restrictions on carried-forward losses introduced on 1 April 2017.

Issue: 1493
Categories: News
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