Taxation logo taxation mission text

Since 1927 the leading authority on tax law, practice and administration

Property poser

05 January 2010
Issue: 4237 / Categories: Forum & Feedback , Business , Income Tax
A UK buy-to-let property is owned by a company registered in the British Virgin Islands. The director is not resident or domiciled in the UK. A charge to UK income tax will arise on the rental income

I have recently been asked to act for a client who is non-resident and non-domiciled in the UK. He has acquired a buy-to-let property in the UK but the property itself is owned by a British Virgin Islands registered company. He is the only director and shareholder of that company.

As far as I can see there should be no tax liability in the UK because the company is managed and controlled abroad and he himself has no connection with the UK other than with this property. He is convinced that there is a UK tax liability and has asked me to make the appropriate returns to HMRC.

Assuming that he is right what form or return needs to be made to the UK tax authorities and what period would be covered by such a return?

Query 17 525 – Bemused

Reply from JCS

Payment of rent...

If you or your firm subscribes to Taxation.co.uk, please click the login box below:

If you are not a subscriber but are a registered user or have a free trial, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this item in full.

Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.

back to top icon