Company residence and UK presence
We establish the company's incorporation, management position and whether it has a UK permanent establishment or other UK registration requirement.
An overseas company owning UK property can have UK Corporation Tax obligations even though the company itself is not UK resident. Rental profits, finance costs, property disposals, the Non-Resident Landlord Scheme and ATED can all sit within the same ownership structure.
We first establish whether the company is genuinely non-UK resident, what UK property it owns and how the property is used. The tax analysis then follows the company and transactions rather than assuming overseas incorporation keeps UK property outside UK Corporation Tax.
Approximate figures are sufficient for the initial enquiry. Please do not upload sensitive company records here.
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The core work is usually UK Corporation Tax on rental profits and property gains, together with the company return, accounts and any separate property-specific obligations.
A genuinely non-UK resident company can still be within Corporation Tax because it carries on a UK property business, receives other UK property income or disposes of UK land.
The engagement is built around the company's UK property activity rather than treating it as an ordinary UK-incorporated property company.
We establish the company's incorporation, management position and whether it has a UK permanent establishment or other UK registration requirement.
Gross rents, property expenditure and relevant financing amounts are brought into the Corporation Tax computation.
Where appropriate, we consider the company's gross-payment position and tax already deducted from UK rental income.
The company accounts and UK property tax computation are prepared for the relevant Corporation Tax filing.
Direct or relevant indirect UK property disposals are reviewed under the Corporation Tax rules applying to non-resident companies.
Where the company owns higher-value UK dwellings, ATED and any relevant relief filing are considered separately.
The UK tax return needs to connect the foreign company's accounting records with the UK property activity and the specific Corporation Tax rules that apply.
We confirm incorporation, residence, accounting period, UK registrations and ownership of the UK property.
Rental income, property expenditure, financing and any NRLS deductions are brought together.
Corporation Tax rules are applied to the company's UK property profits and any relevant gains.
The return, tax computation and relevant accounts are provided for approval before electronic submission.
Since 6 April 2020, UK property-business profits of non-UK resident companies have been within Corporation Tax. Gains on UK land have been brought within Corporation Tax for non-resident companies since 6 April 2019.
The individual residential-landlord mortgage-interest restriction should not simply be copied across to an overseas company. Company financing is dealt with under the Corporation Tax framework, including the relevant loan-relationship rules and, for larger or more complex structures, potentially other corporate interest provisions.
HMRC guidance confirms that non-UK resident companies with UK property businesses moved into Corporation Tax from 6 April 2020.
Non-resident companies are within Corporation Tax on gains from UK land and property disposals from 6 April 2019.
An overseas entity can have UK tax, land-registration and corporate transparency obligations without being a normal UK-incorporated company.
These obligations should be separated rather than assuming that one HMRC or Companies House registration covers everything.
Corporation Tax is only one part of the property lifecycle. Acquisitions, disposals, restructuring and residential-property charges can create separate work.
The exact obligations depend on the company's residence, UK presence, property activity and wider group structure.
Yes. A non-UK resident company carrying on a UK property business can be within Corporation Tax on its UK property profits even though the company remains resident overseas.
Where the company is required to deliver a Company Tax Return, its UK property profits are reported within the Corporation Tax framework together with the required tax computation and relevant accounts.
A qualifying non-resident company landlord can apply under the NRL2 process for authority to receive UK rental income without tax being deducted under the Non-Resident Landlord Scheme.
A non-UK resident company without a UK permanent establishment is generally not entitled to the small-profits rate or marginal relief and normally calculates the relevant profits using the Corporation Tax main rate. Treaty or permanent-establishment circumstances can require separate review.
Since 6 April 2019, gains of non-resident companies on UK land and relevant property interests can fall within Corporation Tax rather than the individual 60-day CGT reporting regime.
Potentially. If the company owns a UK dwelling above the ATED value threshold, an ATED filing can be required even where a qualifying relief ultimately reduces the annual charge to nil.
Not necessarily as a UK establishment. However, overseas entities owning relevant UK land can have separate obligations under the Register of Overseas Entities. The two Companies House regimes should not be confused.
No. The individual residential-landlord finance-cost restriction should not simply be applied to a company. Company financing is dealt with under the Corporation Tax rules applicable to the company's borrowing and structure.