We have in recent years seen significant changes to the taxation of UK real estate in the hands of non-UK persons. For example FA 2016 brought offshore companies carrying on a trade of dealing in or developing UK land within the charge to corporation tax even in the absence of a UK permanent establishment. However the FA 2016 changes did not change the taxation of UK rental income in the hands of offshore corporate landlords which remains subject to income tax capped at the basic rate of 20%. FA 2019 will bring those offshore corporate landlords within the scope of corporation tax (and remove them from income tax) with effect from 6 April 2020 thereby levelling the playing field between offshore and UK corporate landlords.
Some of the more interesting aspects of the switch to corporation tax are not to be found in FA...
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