The following Corporation Tax guidance note by Tolley provides comprehensive and up to date tax information covering:
Prior to April 2013, non-resident companies were typically not within the scope of UK corporation tax on chargeable gains, save in respect of capital assets which were used as part of a UK permanent establishment. This offered a particular incentive to non-resident companies investing in UK land. However, from April 2013, there has been a gradual erosion of this tax benefit.
The following legislative measures have diminished the attractiveness of investing in UK immovable property for non-resident persons:
Following consultations in March and November 2017, the Government introduced legislation in FA 2019, Sch 1, to further extend the scope of UK tax on non-residents holding interests in UK land (referred to in the remainder of this guidance note as the ‘FA19 NRCGT regime’).
The changes bring
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