The following Corporation Tax guidance note Produced 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 diminished the attractiveness of investing in UK immovable property for non-resident persons:
from 6 April 2013, disposals of high value UK residential property by non-resident companies, partnerships with a corporate member and collective investment schemes became subject to CGT at a rate of 28% where the property was chargeable to the annual tax on enveloped dwellings (ATED-related gains). This regime was repealed for disposals made on or after 6 April 2019. It should be noted that while the ATED-related gains regime has been repealed, the ATED charge itself still applies, where relevant. For more on the ATED charge and the ATED-related CGT provisions, see the Overview of the ATED regime guidance note and Simon’s Taxes C2.1125–C2.1129A
from 6 April 2015, a CGT charge applied more generally to non-UK residents disposing of UK residential property. The charge applied to a much broader class of non-UK residents and irrespective of the value of the residential property held. From this date, non-UK resident individuals, closely-held companies, trustees, personal representatives and funds disposing of UK residential property were within the scope of CGT. This regime has been superseded by the FA19 NRCGT regime (see below) for disposals made on or after 6 April 2019. For more information on the former rules, see the Non-resident capital gains tax (NRCGT) on UK residential property (2015–2019 rules) guidance note and Simon’s Taxes C2.1130–C2.1135
From 6 April 2019, 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’) was
**Free trials are only available to individuals based in the UK. We may terminate this trial at any time or decide not to give a trial, for any reason.
Access this article and thousands of others like it free for 7 days with a trial of TolleyGuidance.
Read full article
Already a subscriber? Login
This note offers guidance in respect of the administration of company tax returns. If a company or organisation is subject to corporation tax they will have to complete and file a company tax return for each accounting period. A company or organisation must, in the main, file a return even if they
This guidance note provides details of quarterly instalment payments (QIPs) for corporation tax purposes and which companies need to pay their tax liabilities in this manner.Generally, corporation tax is payable nine months and one day after the end of the relevant accounting period. However, large
Expenditure of a capital nature is not allowed as a deduction when calculating trading profits. Expenditure of a revenue nature is allowable, provided there is no specific statutory rule prohibiting a deduction and the expenditure also satisfies the wholly and exclusively test. See the Wholly and
Business asset disposal relief (previously known as entrepreneurs’ relief) is a capital gains tax (CGT) relief that allows business owners with chargeable gains on qualifying business assets to pay CGT at a rate of 10%. For disposals made on or after 11 March 2020, the relief is available on up to
To view our latest tax guidance content, sign in to Tolley Guidance or register for a free trial.