From 6 April 2020 non-UK resident companies are within the scope of UK corporation tax (currently 19%, but rising to 25% from April 2023) on:

  • Profits from UK property business including profits of "other property income" which includes for example rent for UK electric-line wayleaves.
  • Profits of a "trade of dealing in or developing UK land" are chargeable to UK corporation tax.  The 'trade of dealing in or developing UK land' consists of dealing in UK land; developing UK land for the purpose of disposing of it; and any activities the profits from which are treated as profits of the company's trade of dealing in or developing UK land. 'Land' includes buildings and structures, any estate, interest or right in or over land, and land under water.
  • Profit on the disposal of UK land and buildings held for investment purposes, subject to possible rebasing.