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HMRC to target offshore companies owning UK property

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HMRC is to launch a new campaign in September 2022 to tackle non-compliance linked to offshore corporates which own UK property.

The CIOT reports that the campaign follows a review of data which identified non-resident corporate owners of UK property which ‘may not have met certain UK tax obligations’.

HMRC intends to send out one of two letters (together with a certificate of tax position), depending on the circumstances:

  • to non-resident companies which own UK property and need to disclose income received as a non-resident corporate landlord, or a liability to annual tax on enveloped dwellings - HMRC will also consider the transfer of assets abroad rules for UK-resident individuals who have an interest in the income or capital of a non-resident landlord; and
  • to non-resident companies which appear to have made a disposal of UK residential property between 6 April 2015 and 5 April 2019 without filing a non-resident CGT return.

The CIOT intends to publish a copy of the letters when they become available, and guidance for members whose clients receive the letters.

Issue: 1586
Categories: News
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