The government is proposing to move the property rental income of non-UK resident investment companies away from income tax and, instead, bring it into charge to corporation tax. In many instances, the proposals should have little impact on the UK tax liabilities of such companies and the fact that commercial property gains remain outside UK tax is welcomed. However, there will be implications for some, particularly in relation to both loss relief and the deductibility of finance costs. There are also transitional rules to consider and perhaps a need to address the potential complexity of taxing gains on residential property.
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