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Residential Property Developer Tax (RPDT) applies to certain profits from UK residential development activity, as part of its Building Safety Programme arising from the Grenfell tragedy.

In broad summary, RPDT applies to:

1. •

   UK resident companies and non-resident companies within the charge to UK corporation tax (such as those that have a UK permanent establishment)

2. •

   generating profits from land held as trading stock for residential property development

3. •

   with relevant profits in excess of £25m, and

4. •

   it applies a surcharge rate of 4% on relevant profits

FA 2022, s 34; RPDT10100

Companies will be within the scope of the rules where they undertake residential property development activities in respect of UK land in which they, or a related company, have, or have had, an interest, provided that interest forms, or formed, part of trading stock. Property investment companies (including those using a build-to-rent model) are therefore excluded from the remit of the regime.

Broadly, trading profits for RPDT are calculated as for