HMRC to target offshore companies owning UK property

Offshore corporates that own UK property will be the target of a new campaign by HMRC to tackle non-compliance.

The tax authority has told the Chartered Institute of Taxation that this follows a review of data which identified non-resident corporate owners of UK property that ‘may not have met certain UK tax obligations’. It intends to issue one of two letters (together with a certificate of tax position) depending on the circumstances.

One letter will be sent to non-resident companies that own UK property and need to disclose income received as a non-resident corporate landlord or a liability to annual tax on enveloped dwellings.

The other will go to non-resident companies that appear to have made a disposal of UK residential property between 6 April 2015 and 5 April 2019 without filing a non-resident CGT return.

The CIOT intends to publish a copy of the letters when...