Poole Office: 01202 678555

Wimborne Office: 01202 849169

  • slider-1.jpg
  • slider-2.jpg
  • slider-3.jpg
  • slider-4.jpg

Request a Call Back

Please enter your name and phone number

Latest News

New “Spotlight” explains impact on pensions of maternity leave
18/06/2018 - More...
The Pensions Advisory Service (TPAS) has...

Dormant assets scheme to be expanded
13/06/2018 - More...
The Government has announced that the...

VAT reverse charge may be coming to the construction sector
13/06/2018 - More...
HMRC has launched a new consultation...

Search News

Newsletter

With our newsletter, you automatically receive our latest news by e-mail and get access to the archive including advanced search options!

»Sign up for the Newsletter
» Login

 

Liability of non-resident companies
06/06/2018

Under the current rules non-resident companies with a trading business in the UK are liable to pay UK Corporation Tax on their profits made through a permanent establishment/branch or agency.

There are some differences in the taxation of non-resident companies as opposed to resident companies. For example, a non-resident company:

  • is not liable to account for ACT on distributions made before to 6 April 1999,
  • cannot have 'franked investment income',
  • cannot have surplus franked investment income for the purposes of ICTA88/S242,
  • cannot set trading losses against dividend income to augment its trading income for the purposes of absorbing losses brought forward.

Any UK-source income received by a non-resident company which does not carry on a trade in the UK through a permanent establishment/branch or agency is subject to UK Income Tax on any UK-source income. Any Income Tax due is calculated at the basic rate only without any allowances, subject to any applicable Double Taxation Agreement.

A consultation was published by the government last year to explore whether non-UK resident companies that carry on a UK property business or have other UK property income should be charged to Corporation Tax, rather than being charged to Income Tax as at present.

In a wide-ranging response to the consultation, the government concluded that these non-UK resident companies should become subject to corporation tax in order to help ensure that non-UK resident companies and UK resident companies face the same tax rules and rates on similar types of income.

This change means that corporate landlords will ultimately become subject to Corporation Tax on their income and gains. The changes have not yet been legislated for but are expected to come into effect from 6 April 2020 with legislation to be published in Finance Bill 2018/19 later this year.


Contact Us

Poole Office

Tower House, Parkstone Road
Poole, Dorset
BH15 2JH
Tel: 01202 678555

This email address is being protected from spambots. You need JavaScript enabled to view it.

Company Registration No: O7430971
VAT Registration No.107585703

Wimborne Office

Beaufort House, 2 Cornmarket Court
Wimborne
BH21 1JL
Tel: 01202 849169

Membership

ICAEW-White

Save