Non-resident companies chargeable to income Tax and non-resident CGT - CIOT comments

6 Jul 2017

Our submission along with the consultation document is available to view below in PDF format.

We have received the following response from HMRC:

19 August 2019 Thank you for your representations about CGT, land pooling and equalisation payments. After consideration we think that there is insufficient evidence to take the matter further at this time, however we would like to keep the issue under review. Therefore any further evidence you or colleagues may have, or come across, regarding how this problem is specifically hindering developments would be appreciated. It would also be useful to know how this issue compares in importance to other factors affecting development, for example other aspects of the tax system, planning rules, section 106 / community infrastructure levy, and whether there are regional variations.

One further point is that in the context of developments (including for residential use) government has already provided local authorities with a range of powers, including compulsory purchase, and expects them to make effective use of them, for example to resolve coordination failures. In the case of the compulsory purchase regime, secretary of state MHCLG also announced alongside Spring Statement 19 that the government will consider further reforms in line with the manifesto commitment to make them easier and less expensive for councils to use.

Technical Team