CTA09/S607ZA

Relief for pre-commencement financing costs

From 6 April 2020, a non-resident company which carries on a UK property business, or which has other UK property income, is brought into the scope of UK Corporation Tax. Prior to that date the profits would have been subject to Income Tax.

A non-UK resident company, if it is not carrying on a trade in the UK through a UK permanent establishment or carrying on a trade of developing or dealing in UK land will not have an accounting period until it starts to carry on a UK property business (see PIM2505 for guidance on when a company starts to carry on a UK property business).

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