Disposals of UK land by non-resident companies (NRCG regime) ― overview

Produced by Tolley in association with of Crane Dale Tax, part of AMS Group

Corporation Tax

Guidance

Development of the law

Prior to April 2013, non-resident companies were typically not within the scope of UK corporation tax on chargeable gains, save in respect of capital assets which were used as part of a UK permanent establishment. This offered a particular incentive to non-resident companies investing in UK land. However, from April 2013, there has been a gradual erosion of this tax benefit. See the Direct disposals of interests in UK land by non-residents guidance note for a summary of the changes up to 6 April 2019.

From 6 April 2019, all disposals of interests in UK land by non-residents are within scope of either the CGT or corporate chargeable gains regime. Any overseas entity owning or leasing UK property should register on the Register of Overseas Entities.

This guidance note gives an overview of the rules that apply from 6 April 2019 with a focus on their application to non-resident companies under the ‘NRCG’ rules.

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Rob Durrant-Walker

Tax Director at Crane Dale Tax , Corporate Tax, OMB, Personal Tax

Rob is a cross-tax advisor with a particular focus on property tax planning, and business structure planning for OMB’s. He provides tax advice to other accounting firms, balancing commerciality, ethics, and understanding complexity. His 30+ years of experience start at the Inland Revenue in Hull. After completing his ATT and CTA by 1999 with PKF, he subsequently worked at KPMG and UHY prior to managing the business tax team as a director at Garbutt + Elliott. Rob is now Tax Director at the independent tax consultancy, Crane Dale Tax. He is a regular author for Taxation magazine with many articles and Readers Forum contributions since 2005, and he contributes as a virtual member to the CIOT Property Tax technical committee. Rob works remotely from Vancouver in Canada.

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