Non-resident companies chargeable to income tax and non-resident capital gains tax.
The government is exploring the case and options for bringing non-resident companies with UK taxable income and gains from the disposal of UK residential property interests within the scope of corporation tax.
This would be a fundamental change to the taxation of most non-resident companies that file self-assessment returns but would ensure that the taxation of income from UK real property is consistent. If this were to happen, the policy will include bringing non-resident capital gains tax gains within the corporation tax regime at the same time.
HMRC has published a consultation document on how this might be carried out . Responses should be emailed to nrc.incometax@hmrc.gsi.gov.uk by 9 June 2017.