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Prior to 6 April 2020, all non-resident landlords (NRL) were subject to income tax on UK property rental income. Non-resident companies were subject to a flat rate of income tax (20%) on the rental income.

From 6 April 2020, non-UK resident companies are chargeable to corporation tax rather than to income tax on profits of a UK property business, ‘other UK property income’ and from 6 April 2019 on their corporate gains. There are transitional rules that apply for accounting periods that straddle this commencement date. These are discussed below. The position for NRLs who are not companies is unchanged.

NRLs are subject to the provisions of the non-resident landlords scheme (NRLS). The NRLS continues to apply to non-UK resident company landlords from 6 April 2020. Any income tax deducted under the NRLS can be offset against the corporation tax liability of the company in respect of that rental income. See the Non-resident landlords scheme (NRLS) guidance note for further details.

In addition to the taxation