Commentary

B6.217 Non-resident landlords

Business tax
Business tax | Commentary

B6.217 Non-resident landlords

Business tax | Commentary

Non–resident landlord scheme

B6.217 Non-resident landlords

Non-resident landlord scheme

ITA 2007, s 971 authorises HMRC to make regulations governing the assessment and collection of tax from prescribed 'non-resident landlord representatives' where a UK property business is carried on by a person whose usual place of abode is outside the UK (a 'non-resident')1. These arrangements are called the non-resident landlords scheme (or 'NRLS'). Prior to 6 April 2020, all non-resident landlords (including both companies and individuals) were subject to income tax on the rental income. From 6 April 2020, non-UK resident companies are chargeable to corporation tax rather than to income tax on profits of a UK property business and 'other UK property income' (see D4.122B). The position for non-resident landlords that are not companies is unchanged. However, the NRLS continues to apply to non-UK resident company landlords from 6 April 2020 and any income tax deducted under the NRLS can be offset against the corporation tax liability of the company in respect of that rental income2.

A non-resident landlord representative is:

  1.  

    •     a person who makes payments to the non-resident of sums which constitute receipts of a UK property business, or

  2.  

    •     a person who acts on behalf of the non-resident in connection with the management or administration of any such business,

who in either case has been issued

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