HMRC has offshore property-owning companies in its sights

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HMRC has launched a renewed clampdown on offshore companies that own properties in the UK that it believes are not paying the taxes due.

The campaign is based on analysis of Land Registry data by HMRC and targets non-resident corporate owners of UK property. It is also expected to direct companies to ask associated individuals to ensure their personal tax affairs are up to date.

Whilst the exact date of the campaign is not known, it is believed it will start this month (September 2022), taking the form of two letters accompanied by a Certificate of Tax Position depending on the individual circumstances.

The Chartered Institute of Taxation reports that one letter will be issued to “non-resident companies that own UK property” and who “may need to disclose income received as a non-resident corporate landlord or a liability to the Annual Tax on Enveloped Dwellings (ATED)”.

The second letter will be issued to “non-resident companies that appear to have made a disposal of UK residential property between 6 April 2015 and 5 April 2019 without filing a Non-Resident Capital Gains Tax (NRCGT) return”.

These letters should not be ignored even in the company believes that no taxes are due. Likewise, companies are urged to take advice on how best to respond before they engage with HMRC.

Speak to your usual Hillier Hopkins advisors: or get in touch with Antony Smith who’s contact details are at the bottom of the page.

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Anthony Smith - Director at Hillier Hopkins

Antony has extensive knowledge of UK and international tax, offshore structures and trust and estate planning. His particular focus is on long term wealth planning for families and finding tax efficient solutions to complex situations.

Contact Antony at or on +44 (0)20 7004 7148