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My client is a non-UK resident company. It has various foreign investments which generate income and gains but its only UK income is rental income and some UK interest and dividends. It is properly managed and controlled from overseas and I am happy that it is not resident in the UK.
The UK interest and dividends are not taxable in the UK by virtue of ITA 2007 s 815 and s 825 (disregarded income). The UK rental income has always been reported on a SA700 and charged to income tax. However from 6 April 2020 the rental income is subject to corporation tax and must be reported on a CT600.
My question is whether the move to corporation tax has any effect on the UK interest and dividends? Are they still subject to income tax and therefore remain disregarded income or do they...
