Transactions in UK land

Produced by Tolley in association with of Crane Dale Tax

Corporation Tax

Guidance

Article Summary

This guidance note explains the UK tax rules for transactions in UK land that apply from 8 March 2017. These rules tax profits from dealing in or developing UK land as trading income rather than as capital gains. The rules apply widely to UK and non-UK resident companies and bring many land transactions within the charge to UK corporation tax that were not previously taxable in the UK. A company meeting certain conditions in relation to UK land will be treated as carrying on a trade and taxed on the profits of disposing of the land. Even where there is no UK permanent establishment, non-resident companies can come within the charge to corporation tax on profits from dealing in or developing UK land. The rules contain targeted anti-avoidance provisions to counteract arrangements aimed at avoiding UK tax. Given the wide scope of these rules, companies undertaking transactions concerning UK land should review the position to establish if these provisions apply.

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Rob Durrant-Walker

Tax Director at Crane Dale Tax , Corporate Tax, OMB, Personal Tax

Rob is a cross-tax advisor with a particular focus on property tax planning, and business structure planning for OMB’s. He provides tax advice to other accounting firms, balancing commerciality, ethics, and understanding complexity. His 30+ years of experience start at the Inland Revenue in Hull. After completing his ATT and CTA by 1999 with PKF, he subsequently worked at KPMG and UHY prior to managing the business tax team as a director at Garbutt + Elliott. Rob is now Tax Director at the independent tax consultancy, Crane Dale Tax. He is a regular author for Taxation magazine with many articles and Readers Forum contributions since 2005, and he contributes as a virtual member to the CIOT Property Tax technical committee. Rob works remotely from Vancouver in Canada.

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