Beta This part of GOV.UK is being rebuilt – find out what beta means

HMRC internal manual

COTAX Manual

Case records:New company records:Offshore property developers

Offshore property developers

Before Budget 2016, a non- resident company was chargeable to UK Corporation Tax only where the profits were attributable to a UK Permanent Establishment.  Budget 2016 changed the relevant legislation so that non-resident corporates and non-resident companies  are now within the charge to Corporation Tax on the full profit from carrying on a trade of dealing in or developing UK land.

Such companies do not have to incorporate at Companies House.

You may therefore be approached by a company that has profits that are now chargeable to Corporation Tax, asking for a record to be set up so they may submit returns.

You should do that by:

  • using the company status ‘O’ as the company will not have a Company Registration Number
  • using the date on which the company came within the charge to Corporation Tax as the date of incorporation
  • not making the APs dormant or exempt so COTAX will issue notices to deliver a return at appropriate intervals.

BIM60515 onwards has more information.