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HMRC internal manual

International Manual

The Non-resident Landlords Scheme: Usual place of abode

The Non-resident Landlords Scheme applies to people who pay UK rent to landlords whose usual place of abode is outside the UK.

Individuals

Individuals have a usual place of abode outside the UK if they usually live outside the UK. But individuals are not regarded as having a usual place of abode outside the UK if they are living outside the UK only temporarily (say, for six months or less).

Companies

Companies that have their main office or other place of business outside the UK, and companies incorporated outside the UK, normally have a usual place of abode outside the UK. However, companies regarded as resident in the UK for tax purposes do not have a usual place of abode outside the UK for the purposes of the Scheme, even though they may be incorporated outside the UK.

The UK branch of a non-resident company, where that branch is within the charge to Corporation Tax, does not have a usual place of abode outside the UK for the purposes of the Scheme.

Trustees

Trustees have a usual place of abode outside the UK if all the trustees have a usual place of abode outside the UK (following the rules for individuals and companies, as appropriate). If one or more of the trustees does not have a usual place of abode outside the UK, the trustees are not a non-resident landlord for the purposes of the Scheme.