Transactions in UK land

Produced by Tolley in association with of Crane Dale Tax, part of AMS Group

Corporation Tax

Guidance

The rules on taxing the profits of dealing in and developing UK land introduced by FA 2016 replace the previous legislation on transactions in land. The rules are widely drafted and catch all persons undertaking transactions in UK land and property, whether resident in the UK or resident outside the UK.

The rules apply to profits recognised in the accounts on or after 8 March 2017, regardless of the date of the contract, ie even if the contract was entered into prior to 5 July 2016 (the date upon which the legislation came into force).

This guidance note covers the latest rules as they apply for corporation tax purposes. The pre-2016 rules for corporation tax are covered in Simon’s Taxes at B5.235 onwards.

Similar provisions apply for income tax as explained in the Transactions in UK land ― individuals guidance note.

HMRC has confirmed that it is not the purpose of the rules to alter the treatment of the activity if it is clearly investment. Transactions

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Rob Durrant-Walker

Tax Director at Crane Dale Tax , Corporate Tax, OMB, Personal Tax

Rob is a cross-tax advisor with a particular focus on property tax planning, and business structure planning for OMB’s. He provides tax advice to other accounting firms, balancing commerciality, ethics, and understanding complexity. His 30+ years of experience start at the Inland Revenue in Hull. After completing his ATT and CTA by 1999 with PKF, he subsequently worked at KPMG and UHY prior to managing the business tax team as a director at Garbutt + Elliott. Rob is now Tax Director at the independent tax consultancy, Crane Dale Tax. He is a regular author for Taxation magazine with many articles and Readers Forum contributions since 2005, and he contributes as a virtual member to the CIOT Property Tax technical committee. Rob works remotely from Vancouver in Canada.

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