HMRC update: Non-resident companies chargeable to Income Tax & non-resident CGT
Simon Vardon, Director, Product Development – Real Estate
On 20 March 2017 HM Revenue & Customs published a consultation paper entitled “Non-resident companies chargeable to Income Tax and non-resident CGT”. Broadly, the proposals involve a non-resident company currently subject to income tax in the UK being brought within the scope of UK corporation tax.
It may be recalled that on 16 March 2016 the then Chancellor, George Osborne announced that with effect from 1 April 2017 a number of measures proposed under the BEPS recommendations by the OECD would be introduced to the UK corporation tax legislation. These were enacted by the Finance Bill 2017. Thus, one of the main drivers of the proposals is to include non-resident companies within the scope of the new BEPS related rules, which HMRC are proposing is most efficiently undertaken by bringing non-resident companies within the scope of corporation tax.