Autumn Budget 2017: Non-UK resident companies and Corporation Tax

The Government has announced that income and Capital Gains from UK properties owned by non-UK resident companies will now be chargeable to Corporation Tax rather than Income Tax.
Following recent consultation, the Government has also announced that from April 2020, income that non-UK resident companies receive from UK property will be chargeable to Corporation Tax rather than Income Tax and that capital gains that arise on the disposal of UK property will also be charged to Corporation Tax as opposed to Capital Gains Tax.

This change is aimed at ensuring that the interest restriction that applies to companies within Corporation Tax applies to those who are not UK resident but have UK income that may be funded by borrowing.

Those with significant property portfolios held through non-UK companies should seek an early review of the structure to ensure that the financing arrangements remain suitable and the returns remain as intended.

Further information on the impact of the Budget can be found here.
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