New Forest


HMRC “nudging” offshore corporate property owners

HMRC may send a nudge letter to taxpayers whose tax affairs do not appear to be in order.

As part of a new campaign, HMRC have used Land Registry data to identify offshore companies that own UK property. If HMRC suspects that the landowner has not met its UK tax obligations, they will issue one of two nudge letters.

The two types of nudge letter are as follows:

  • A letter to non-UK resident companies who may need to declare income received as a non-resident corporate landlord, or pay Annual Tax on Enveloped Dwellings (ATED). Although this letter will be addressed to the company, it will recommend that UK-resident individuals who have an interest in the income or capital of the company ensure that their tax affairs are up to date, particularly in relation to the Transfer of Assets Abroad anti-avoidance legislation.
  • A letter to non-UK resident companies who appear to have disposed of UK residential property between 6 April 2015 and 5 April 2019 without submitting a non-resident capital gains tax return.

HMRC do not issue nudge letters automatically, so if you receive one, do not ignore it. We advise you to speak to us as soon as possible.

For further information, please contact Tom Young on 023 8046 1254

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