From 6 April 2020, non-UK resident companies are chargeable to corporation tax rather than to income tax on profits from a UK property business and on 'other UK property income'1.
Essentially, from this date, the tax treatment of non-resident companies carrying on a UK property business mirrors the treatment that applies to UK resident companies carrying on such a business.
The non-resident company is chargeable to corporation tax on the profits of its UK property and (separately) profits on loan relationships or derivatives which enable the company to generate the property income. The latter will be dealt with as non-trading loan relationships, rather than as part of the UK property business2.
It is only loan relationship debits and credits that relate to the UK property business that are within the scope of UK corporation tax. Therefore, if a non-resident company carries on other activities (for example, it owns non-UK properties), it is necessary to stream the relevant UK and non-UK loan relationship debits and credits accordingly.
'Other UK property
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Web page updated on 17 Mar 2025 15:59