Two weeks to 21 February 2020
Welcome to our latest update on recent developments in international and treasury tax of interest to multinationals operating in the UK.
The UK has left the EU, but that’s not the end of the Brexit story. As negotiations on the future trading relationship of the UK and the EU start, and trade discussions begin with countries around the world, how will you remain agile to respond to the risks and opportunities this new world presents? Visit our Beyond Brexit webpage for the latest updates. In particular please note:
UK's approach to tackling profit diversion - Webcast, 27 February, 9pm UK
HMRC will participate on a webcast panel with PwC to present on its latest operational approach to mitigating profit diversion by multinationals operating in the UK. In particular, the HMRC officials will talk through why this approach is important now and how the Diverted Profits Tax and the Profit Diversion Compliance Facility, a new co-operative compliance initiative, fit into this framework. Register here.
Changes to the regulations for the Non-resident Landlord Scheme
From 6 April 2020, non-resident corporate landlords that carry on a UK property business or have other UK property income, will be subject to UK corporation tax (CT) on their property income rather than income tax (IT) as they are currently. The Non-Resident Landlord Scheme (NRLS) will continue to apply, with any IT deducted being available for offset against that CT liability. In anticipation of that change, the NRLS regulations have been amended to introduce the ability to elect to apply a simplified alternative rule governing the deductibility of finance costs in place of the CIR (Corporate Interest restriction) rules that would otherwise now apply. See here.