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FA19/Sch 5/Para 48

From 6 April 2020, non-resident companies receiving UK property income will be chargeable to Corporation Tax instead of Income Tax on this income.

Where a non-resident company is chargeable to Income Tax on its property income immediately before 6 April 2020 and becomes chargeable to Corporation Tax on 6 April 2020, an accounting period for Corporation Tax purposes will commence on 6 April 2020. The instalment payment regulations will not have effect in relation to that first accounting period in which the company becomes chargeable to Corporation Tax聽. This means that no instalment payments will be needed, regardless of whether the company is 'large' or 'very large' for instalment payment purposes.

Example

A non-resident company receiving UK property income and with an accounting period ended 30 September 2020 will have a first accounting period of 6 April 2020 to 30 September 2020. This period is ignored for instalment payment purposes.

In the next accounting period to 30 September 2021, it has profits of 拢1,600,000.聽It does not have to make instalment payments for this period even though it is 'large' for instalment payment purposes as Reg 3 provides an exemption for the first period in which the company is 'large.'聽聽

The聽instalment payment regime聽will apply as normal to the next and all subsequent accounting periods.