What is a UK property business under Corporation Tax Act 2009 section 205?

Under section 205, a UK property business encompasses every business a company carries on to generate income from land in the United Kingdom. It also includes any one-off transactions entered into for the purpose of generating income from UK land, even where those transactions do not form part of a continuing business.

What is the one business per company rule in section 205 CTA 2009?

The one business per company rule means that all of a company's UK land income activities are aggregated into a single UK property business. Rather than treating each property or letting arrangement separately, profits and losses from different properties are combined when calculating the taxable result for corporation tax purposes.

Does section 205 cover one-off land transactions for corporation tax?

Yes, section 205 has two limbs. The second limb captures any individual transaction a company enters into for the purpose of generating income from UK land, even where that transaction does not form part of a continuing business. This ensures isolated or one-off land-related income transactions are not overlooked.

Are there exceptions to the single UK property business rule under section 205?

Yes, although section 205 establishes the general principle that all UK land income forms a single business, certain special cases may be treated separately from the single UK property business. These exceptions are provided for in other sections of the Corporation Tax Act 2009.

Corporation Tax Act 2009 section 205

UK property business

Section 205 defines what constitutes a company's UK property business for corporation tax purposes, establishing that all land-related income activities are treated as a single business.

A UK property business covers every business a company carries on to generate income from land in the United Kingdom.
It also includes any one-off transactions entered into for the purpose of generating income from UK land, even if they are not part of an ongoing business.
All income from a company's various UK land interests is treated as falling within a single UK property business — the "one business per company" rule.
Certain special cases may be treated separately from the single UK property business, as provided for elsewhere in the Act.

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