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GLOSSARY

Non-resident landlords scheme (NRLS) definition

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What does Non-resident landlords scheme (NRLS) mean?

Requires income tax at the basic rate to be deducted from rental payments due to non-resident landlords in respect of a UK property business and accounted for to HMRC.

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Key UK tax issues arising on the sale and purchase of an SPV owning UK commercial property

Key UK tax issues arising on the sale and purchase of an SPV owning UK commercial property Tax is a key consideration when selecting an appropriate structure for holding UK commercial property. The most common form of investment in UK commercial property is the UK incorporated and tax resident limited company. For non-UK investors, there has been a trend towards offshore ownership for investment purposes through a non-UK resident special purpose vehicle (SPV). Following changes to the taxation of gains made by non-UK residents on UK immovable property from 6 April 2019 and to the taxation of property income for non-UK resident companies from 6 April 2020, non-UK resident companies holding commercial UK property have been brought within the scope of UK corporation tax in respect of gains (subject to some exemptions) and rental income. As a result, some of the key tax incentives for using non-UK resident SPVs to hold UK commercial property have been removed. However, acquiring UK commercial property via an offshore SPV...

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