The Government is considering bringing all non-resident companies receiving taxable income from the UK into the UK corporation tax regime. At the Spring Budget in 2017, the Government will consult on implementing this change. The Government wants to deliver equal tax treatment to ensure that all companies are subject to the rules which apply generally for the purposes of corporation tax, including the limitation of corporate interest relief and loss relief rules.
It is not clear what impact these changes will have as offshore companies usually pay income tax at 20% on their UK income profits. However, they do not at present pay tax on any gains on the sale of UK commercial properties and it will be interesting to see if they are now proposing to tax such gains. The limitation of corporate interest relief and loss relief rules will only impact large groups.
Date: 24th November, 2016
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