We have seen a lot of new legislation targeted at non-resident companies over the last couple of years as HMRC tackle tax avoidance through the use of offshore structures and April 2020 brings yet another change!
From April 2019, we saw the move from non-resident capital gains tax (NRCGT) to corporation tax for UK land and property disposals by non-resident companies, meaning that a one-day corporation tax return was required for any disposal of UK land and property in the 2019/20 tax year, alongside the completion of an income tax return for income derived from UK land and property during the tax year.
From April 2020, non-resident companies move entirely across to being charged to corporation tax, so that an annual corporation tax return is required for the company to include income and any disposals.
Companies will automatically be registered for corporation tax and new company tax references will be issued by HMRC to bring the company within the corporation tax regime. There will also be several transitional rules with regard to losses, capital allowances and payments on account.