Companies Incorporated or Tax Resident Overseas

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Companies which are incorporated and/or tax resident overseas and which are subject to UK corporation tax, will pay a flat rate of 25% corporation tax on taxable profits arising after 1 April 2023.

This 25% rate will apply to all UK based property and trading income and to capital gains on all sales of UK investment property.

Action could be taken ahead of 1 April 2023, to mitigate some of the implications of these japan mobile database changes. Any proposed action would, however, need to be assessed to ensure it makes commercial sense and take into account any prevailing case law and HMRC practice. Professional advice from a company such as Dixcart should be taken.

The Option of De-enveloping UK Property Held in a Non-UK Resident Company
If the de-enveloping of UK properties being held by non-UK resident companies is being considered, this should take place as far ahead of 1 April 2023, as possible.

Each situation needs to be considered based on its merits and an evaluation needs to take place as to whether this is the most appropriate action, from both a tax and a wider perspective. Any decision also needs to take into account that it might take some time to put changes in place to achieve the desired end result.