Non-resident landlords scheme (NRLS)

Produced by Tolley in association with of Crane Dale Tax

Corporation Tax

Guidance

Although the UK does not generally tax non-residents (see the Residence of companies and Residence ― overview guidance notes), it does apply tax in respect of UK source income, and in particular in respect of rental income from UK properties.

Prior to 6 April 2020, all non-resident landlords (NRL) (including both companies and individuals) were subject to income tax on the rental income. Non-resident companies were subject to a flat rate of income tax of 20% on the property income. Depending on the level of the income, non-resident individuals were subject to tax at the default income tax rates of 20%, 40% or 45%.

From 6 April 2020, non-UK resident companies are chargeable to corporation tax rather than to income tax on profits of a UK property business and ‘other UK property income’. For more information on the changes, see the Non-resident landlords ― rules for companies from April 2020 guidance note.

Without special provisions, non-UK resident landlords could

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Rob Durrant-Walker

Tax Director at Crane Dale Tax , Corporate Tax, OMB, Personal Tax

Rob is a cross-tax advisor with a particular focus on property tax planning, and business structure planning for OMB’s. He provides tax advice to other accounting firms, balancing commerciality, ethics, and understanding complexity. His 30+ years of experience start at the Inland Revenue in Hull. After completing his ATT and CTA by 1999 with PKF, he subsequently worked at KPMG and UHY prior to managing the business tax team as a director at Garbutt + Elliott. Rob is now Tax Director at the independent tax consultancy, Crane Dale Tax. He is a regular author for Taxation magazine with many articles and Readers Forum contributions since 2005, and he contributes as a virtual member to the CIOT Property Tax technical committee. Rob works remotely from Vancouver in Canada.

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