HMRC One to Many letter – non-resident corporate landlords owning non-residential property in the UK

14 Aug 2023

HMRC have recently started sending a letter to certain non-resident companies that own non-residential property in the UK. The letters target those companies that appear to have failed to notify for tax where they own commercial property. The companies may need to disclose rental income to HMRC and the letters explain what they need to do next. A copy of the letter and the accompanying Certificate of Tax Position are provided below. 

NRL commercial OTM letter

The letter is linked to HMRC’s ongoing programme of work to identify and tackle potential non-compliance by offshore corporates owning UK property. For information about other letters HMRC have been issuing and guidance the CIOT has produced to assist members in deciding the most appropriate way to respond should a client receive a letter from HMRC, see our news items Offshore Corporates Owning UK Property – HMRC letter campaign and Guidance for CIOT members and UK residential property and the Annual Tax on Enveloped Dwellings (ATED) – HMRC letter campaign.