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HMRC updates guidance on accounts for non-resident corporate landlords


Published: 28 Jun 2022 Update History

Some uncertainty has arisen over the nature of accounts that need to be submitted with tax returns for non-UK resident companies with UK rental profits. HMRC has now updated its guidance to make the position clear.

Since April 2020, non-UK resident companies have been subject to corporation tax on rental profits arising on their UK properties. HMRC has clarified the accounts requirement for non-resident companies with UK rental profits (but no UK permanent establishment) in various scenarios by updating its COTAX Manual at COM130010.

Companies that are subject to corporation tax are required to submit returns for accounting periods ending after 31 March 2010, through the Corporation Tax Online Service. The tax computations submitted must be in inline Extensible Business Language (iXBRL) format.

The accounts must also be in iXBRL, unless the return is for an unincorporated charity, club or society, or a company that is neither resident nor incorporated in the UK. In that case, they may be in iXBRL or, in some cases, PDF format. There are separate rules for UK permanent establishments of non-UK resident companies.

HMRC’s updated guidance makes it clear that iXBRL accounts are required if the company’s accounts are prepared using an accounting standard that is supported by an XBRL taxonomy that is accepted by HMRC (currently UK GAAP, IFRS and US GAAP).

If the company’s accounts are not so prepared, then those accounts should instead be submitted as a PDF attachment to the online return. In that case, a UK GAAP/IFRS profit and loss account (P&L) for the UK property business must also be included in the corporation tax computation, in iXBRL format, using the corporation tax computational taxonomy.

Such a P&L in iXBRL format must also be filed if the accounts are prepared under US GAAP (despite the fact that this is an accounting standard supported by an XBRL taxonomy accepted by HMRC).

If the company does not produce accounts, it only needs to include a UK GAAP/IFRS P&L for the UK property business in the corporation tax computation. The P&L should be tagged in iXBRL format using the corporation tax computational taxonomy.

These various scenarios are also set out in a tabular format in a standalone document: Company Tax Returns: format for accounts forming part of an online return

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