This Practice Note explains what profits relating to real property (ie real estate and land) are required to be brought into a UK corporation tax calculation under the heading for property income. It explains the principles for making the calculations; the meaning of a UK and overseas property business, including the meaning of generating income from land; and specific items that must be included and excluded from that calculation. It also sets out the territorial scope of the UK corporation tax charge on property income including when a non-UK resident company is subject to corporation tax in respect of a property business. The charge to UK corporation tax applies to the profits of both UK and overseas property business and this Practice Note is about that charge as it applies to income. A property business is one that generates income from land and includes every transaction entered into for that purpose. A UK resident company is subject to corporation tax on the profits of both UK and overseas property businesses (save for any profits that

Forthcoming change: Sections 6–7 of the Finance Act 2026 provide that (with effect from 6 April 2027) an individual’s property income will be charged to income tax at the property basic rate (22%), the property higher rate (42%) and the property additional rate (47%) for a tax year. A person’s property income will be treated as the highest part of their income, except for where they have savings and/or dividend income. Where a person has savings and/or dividend income, any property income should be treated as the part of the person’s income immediately before the savings and/or dividend income. FA 2026, Schedule 1 makes consequential amendments to ITA 2007. For these purposes, property income is defined as income which is: • chargeable under Chapter 3 of Part 3 of ITTOIA 2005 (the profits of a UK property business or an overseas property business) • chargeable under Chapter 7 of that Part • chargeable under Chapter 8 of that Part • chargeable under Chapter 9 of that Part, and • chargeable under Chapter 10 of that

Indemnity clause 1 Without limiting any other rights that the Buyer may have, including

1 [ Indemnity provided by the seller Without limiting any other rights that the Buyer may have, including its rights to claim

Insurance & Reinsurance analysis: The Court of Appeal has allowed Sky’s appeal against the judgment of His Honour Judge Pelling KC, and dismissed the cross-appeal of the Insurers, and in doing so has provided authoritative guidance on key principles applicable to construction all risks (CAR) insurance (and indeed property insurance in general). The judgment provides important clarification on four key issues—the meaning of ‘damage’; cover for deterioration/development of insured damage after the expiry of the policy; the recovery of investigation costs; and ‘any one event’ aggregation/deductible provisions. Written by Crispin Winser KC, barrister at Crown Office Chambers, who appeared as counsel for Sky both in the Commercial Court and in the Court of Appeal.

A Limited Liability Partnership whose business consists wholly or mainly in the making of investments in land and the principal part of whose income is derived from that business.

The Insolvency Service has reported that Sam Eustace, 36, from Sutton in South London is now subject to a disqualification undertaking for 11 years. As director of Kingsman Property Ltd, Eustace paid out over £3m to investors between October 2016 and March 2019, but this was funded by money received from new investors rather than any actual return on investment. The company, formerly known as Samuel James Ltd. took at least £6.7m from would-be investors before it went into liquidation in August 2019.

There are a number of ambiguities in the question posed. First, it is unclear whether the property referred to is real property or personalty. Second, it is unclear which interest is being held subject to payment of a debt, ie is it the life interest or the interest of the remaindermen (ie the deceased’s children’s interest)? For the purposes of this Q&A, it is assumed that the property is real property and it is the interest of the remaindermen that is subject to the repayment of a debt. Third, it is unclear whether the interest in remainder was given subject to the debt, whether it was given effectively charged with the debt or whether it was a condition of taking the gift that the beneficiaries would repay the debt. Each would produce a different

A property joint venture is an arrangement between two or more parties under which they combine disparate contributions in order to derive value from the development, acquisition or management of property. The parties who typically participate in property joint ventures include property companies, developers, onshore institutional investors, offshore investors, landowners, local authorities and other public sector organisations.

The Property—horizon scanner tracks key upcoming developments of interest to property lawyers. Once a development occurs, it is moved into the archive for the relevant year. This is the archive for events that occurred in 2017. Appeal cases What happened? When? Find out more Possession proceedings - mesne profits Farrar v Leongreen Ltd [2017] EWCA Civ 2211, [2018] All ER (D) 13 (Jan) The Court of Appeal handed down judgment on 21 December 2017. In Farrar v Leongreen Ltd [2017] EWCA Civ 2211, the Court of Appeal decided that a landlord who had successfully brought possession proceedings against its former tenant was not prevented, due to the principles of res judicata, from starting a new claim on the same grounds to recover mesne profits from that former tenant. The landlord was relying, in the second action, on causes of action distinct from the cause of action on which it had relied in the first action. The position was the same as it would have been if the landlord had been unaware that the former tenant had been in

The Property—horizon scanner tracks key upcoming developments of interest to property lawyers. Once a development occurs, it is moved into the archive for the relevant year. This is the archive for events that occurred in 2018. Appeal cases What happened? When? Find out more Rectification of a registered title—mistake Antoine (Administrator of the estate of Joseph Antoine deceased) v Barclays Bank plc and others [2018] EWCA Civ 2846, [2019] All ER (D) 09 (Jan) The Court of Appeal handed down judgment on 20 December 2018. The Court of Appeal dismissed the appeal against a decision that registration of a party with title to a property following a court order obtained by reference to forged documents was not a ‘mistake’ warranting rectification of the register. Registration on the basis of a valid court order was akin to the position in relation to a voidable transaction, rather than a void one. See News Analysis: Registration pursuant to court order obtained by forgery not a ‘mistake’ (Antoine v Barclays) and Property disposition registration and register of title mistakes (Antoine

The Property—horizon scanner tracks key upcoming developments of interest to property lawyers. Once a development occurs, it is moved into the archive for the relevant year. This is the archive for events that occurred in 2019. Appeal cases What’s happening? When? Find out more Town and village greens — registration and statutory incompatibility R (on the application of Lancashire County Council) v Secretary of State for the Environment, Food and Rural Affairs and another; R (on the application of NHS Property Services Ltd) v Surrey County Council and another, [2019] UKSC 58 The Supreme Court handed down judgment on Wednesday 11 December 2019. The Supreme Court allowed two linked appeals against the Court of Appeal’s ruling against registration of land as a town and village green (TVG). It confirms that land which is acquired and held by a local authority in exercise of general statutory powers which are incompatible with use of that land as a TVG cannot be registered as suchThe central issue in both appeals was the interpretation and application of the principle