Corporation Tax Act 2010 section 520

"UK property rental business" of non-UK companies

Section 520 defines "UK property rental business" for non-UK companies and explains how profits from such business are switched from the income tax regime to the corporation tax regime when the company is a member of a group UK REIT.

• For a non-UK company, "UK property rental business" means its property rental business carried on in the United Kingdom.
• Where a non-UK company is a member of a group UK REIT and its UK property rental profits would otherwise be charged to income tax, those profits are instead treated as chargeable to corporation tax.
• Only profits (not capital gains) are brought within the corporation tax charge, ensuring that gains of non-UK companies without a UK permanent establishment are not inadvertently taxed in the United Kingdom.
• If the REIT rules in this Part apply, the corporation tax charge is removed; to the extent those rules do not apply, the original income tax treatment remains undisturbed.