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In March 2017, the government consulted on the case and options for bringing non-resident companies’ UK property income and gains (previously chargeable to income tax and CGT) into corporation tax. This change would deliver more equal tax treatment for UK and non-resident companies, and take steps to prevent those that use this disparity to reduce their tax bill through offshore ownership. At Autumn Budget 2017, the government announced that it will make this change in April 2020.
The government is exploring the case and options for bringing within the scope of corporation tax, certain non-resident companies with existing UK taxable income and/or gains from the disposal of certain UK residential property interests.