Income tax
ITTOIA 2005, Pt, 3 Ch 12 (ss 361–364) contains additional rules that supplement the provisions dealing with property businesses. Three are dealt with below.
Changes in the composition of trustees and PRs
First, it is provided that a change in the persons who are trustees of a trust or an individual's personal representatives does not amount to any trustee or personal representative starting (or ceasing) to carry on a property business1. In other words, the trusts or the personal representatives are treated as a single continuing body notwithstanding any change in their composition.
Companies coming into or leaving the charge to income tax
Secondly, non-resident companies can be within the charge to income tax on the profits of a UK property business up to 5 April 20202. However, should the company become UK-resident (because of a change in the location of the control and management of the company) it will cease to be subject to income tax and will instead be subject to corporation tax on the profits
To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to Tolley+™ Research or register for a free trial
Web page updated on 17 Mar 2025 17:16