Corporation tax for offshore corporate landlords

The draft Finance Bill extends the scope of corporation tax to non-UK companies carrying on a UK property business (or which have other UK property income), with effect from 6 April 2020. The draft legislation provides more detail on some of the key areas identified in consultation, such as ensuring profits are neither taxed twice nor left out of account as a result of the switch from income tax to corporation tax, and the utilisation of losses incurred under the income tax regime against profits subject to corporation tax, although areas of uncertainty remain.