Consultation outcome

Non-resident companies chargeable to income tax and non-resident capital gains tax

This consultation has concluded

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Detail of outcome

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.

Original consultation


The consultation concerns certain non-resident companies liable to UK income tax and/or capital gains tax, focusing on UK property business.

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Consultation description

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.


Non-resident companies chargeable to Income Tax and non-resident CGT

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Published 20 March 2017
Last updated 1 December 2017 + show all updates
  1. Published summary of responses document.
  2. First published.