Possible Blow to Non-Resident Property Investment Companies
The Government will consult on proposals to bring certain income streams of non-resident companies, which are currently charged to income tax, within the charge to corporation tax. This measure will almost certainly impact on non-resident companies receiving rental income from UK real estate. Any changes are likely to ensure that non-resident companies are subject to the rules which apply to UK resident companies, including the new rules for the limitation of tax relief for corporate interest expense and restriction of losses carried forward being introduced from April 2017.
A consultation on these proposals will take place in March 2017 so they are unlikely to be effective until April 2018 at the earliest.
For further information contact Gavin Stebbing.