Direct tax treatment of property ownership

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Practice notes
Share sale or asset sale—tax considerationsThe sale of a company's business can be structured as either:•a sale of assets owned by the company (an...
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19th May
Practice notes
VAT—triangulationIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following...
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Produced in partnership with John Fuszard of Sagars Accountants Ltd 19th May
Practice notes
What is an intangible fixed asset?Part 8 of the Corporation Tax Act 2009 (CTA 2009) is a specific corporation tax regime that applies exclusively to...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th May
Practice notes
VAT treatment of damages and compensation paymentsFORTHCOMING CHANGE: HMRC is in the process of revising Revenue and Customs Brief 12 (2020) on the...
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19th May
Practice notes
Key tax consequences of an insolvent liquidationThis Practice Note outlines:•the main corporation tax consequences when a UK incorporated company...
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Produced in partnership with Julia Fox of Deloitte LLP and Anthony Davis 19th May
Practice notes
Amortisation of intangible fixed assetsWhere a company acquires (or otherwise incurs capitalised expenditure upon) an intangible fixed asset that...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th May
Practice notes
EIS—deferred gain becomes chargeable to CGTCoronavirus (COVID-19): In response to the coronavirus (COVID-19) pandemic, the government introduced a...
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19th May
Practice notes
Property holding structures—SDLT and VAT treatment of a Jersey Property Unit Trust (JPUT)IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the...
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19th May
Practice notes
VAT on composite suppliesSingle composite supplies vs multiple suppliesWhere a supply comprises a number of different elements with varying VAT...
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Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 19th May
Practice notes
Offshore receipts in respect of intangible property (ORIP)Since 6 April 2019, a person that is neither UK tax resident nor resident in a full treaty...
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19th May
Practice notes
FATCA in the UK—the UK:US Intergovernmental Agreement: an outlineIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 19th May
Practice notes
Tax considerations on a loan agreement—the tax gross up clauseIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Eloise Walker of Pinsent Masons 19th May
Precedents
1 Withholding and grossing up 1.1 All sums payable under this [Agreement] by or on behalf of any party (for the...
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19th May
Practice notes
Section 198 and 199 elections on transactions involving real estateThis Practice Note describes the law and practice relating to elections under...
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Produced in partnership with Martin Wilson 19th May
Practice notes
Taxation of UK LLPsA UK limited liability partnership (LLP) is a body corporate for company law purposes, but is generally taxed as though it were a...
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19th May
Practice notes
SDLT group reliefFORTHCOMING CHANGE relating to FA 2008, Sch 36: In its Tax Information and Impact Note (TIIN) on freeports, the government announced...
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19th May

Most recent Direct tax treatment of property ownership content

Q&As
What are the UK tax issues to consider on the merger of two non-UK companies that own UK residential property (the shareholders are offshore)?There...
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1st Aug
Q&As
What does ‘qualifying trade’ mean in relation to the exemption from the NRCGT rules contained in paragraph 5 of Schedule 1A to the Taxation of...
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1st Aug
Q&As
What are the tax implications for a property management company whose shares are owned by leaseholders in the property granting an extension to leases...
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1st Aug
Q&As
Do the rules that tax profits from trading in and developing UK land affect the UK withholding tax rules?The rules introduced in Finance Act 2016 (FA...
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1st Aug
Q&As
A company owns the freehold in two properties, which it leases to its two sole members and directors. What are the corporation tax on chargeable gains...
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31st Jul
Q&As
Can an individual deduct the costs of demolishing a property and then building a block of flats in its place from any profit or gain it makes on...
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31st Jul
Practice notes
What constitutes a UK permanent establishment in a property context?This Practice Note looks at what constitutes a UK permanent establishment (PE) in...
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Produced in partnership with Charles Goddard of Rosetta Tax 31st Jul
Practice notes
Non-resident landlords schemeThe Non-resident Landlords Scheme (NRL Scheme) requires income tax at the basic rate to be deducted from rental payments...
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31st Jul
Practice notes
Property income—the corporation tax chargeThe charge to UK corporation tax applies to the profits of both UK and overseas property business.A property...
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31st Jul
Practice notes
Real estate—anti-avoidance: sale and leasebacks, taxing lease receipts as income and general anti-avoidance rulesThis Practice Note, together with...
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Produced in partnership with Charles Goddard of Rosetta Tax 31st Jul
Practice notes
Claiming relief under a double tax treaty in relation to income or gains from UK real estateMany investors in UK property are based outside the UK....
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Produced in partnership with Charles Goddard of Rosetta Tax 31st Jul
Practice notes
Profits from trading in and developing UK land (transactions in UK land)At Budget 2016 the government announced rules to tax profits from trading in...
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31st Jul
Practice notes
UK source interest in a property contextFor a UK taxpayer carrying on a real estate-related business in the UK, whether it be trading or investing in...
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Produced in partnership with Charles Goddard of Rosetta Tax 31st Jul
Practice notes
What can an income tax payer do with property losses?The charge to UK income tax applies to the profits of both a UK and overseas property business. A...
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31st Jul
Practice notes
Non-resident CGT—summary [Archived]ARCHIVED: This Practice Note gives an overview of the non-resident capital gains tax (NRCGT) charge that applied...
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Produced in partnership with Alison Cartin of Taylor Wessing LLP 31st Jul
Practice notes
Property developers—direct taxation of trading in UK propertyA key concern for those engaged in a trade of developing property situated in the UK is...
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Produced in partnership with Charles Goddard of Rosetta Tax 31st Jul
Practice notes
What can a company do with property losses?A UK company that has incurred a loss in its UK property business for an accounting period can, in general,...
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31st Jul
Practice notes
Direct tax treatment of overageIn many real estate sale and purchase transactions, the consideration for the sale will include an element of overage....
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Produced in partnership with Charles Goddard of Rosetta Tax 31st Jul

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