Transfer of Assets Abroad rules and UK corporation tax

26 Jan 2024

The Chairs of the Private Client (International) Committee of the CIOT have produced a paper on whether a UK-resident individual should declare, on their personal tax return, the UK rental income received by a non-UK company. HMRC would expect that individual to do so, with the UK corporation tax being allowed as a credit. However, this paper considers that position and the argument that the individual need not disclose that rental income at all.

HMRC have been approached for comment on the specific points made.

Transfer of assets code and corporation tax