Even though capital gains as such are not taxed if made by a non-resident or non-resident company, if there is a portfolio of properties which are turned over regularly, then there is a strong risk that HMRC will still regard the company as trading in properties in the UK, particularly if the degree of leverage is such as to effectively wipe out any net rental income. If a company is trading in the UK via a permanent establishment, then it is subject to Corporation Tax on its trading profits. There are solutions to effectively all problems and we have structures for minimising tax on development project, companies refurbishing and turning over properties on a frequent basis as well as holding for long term investment. Often these arrangements will involve one or more offshore companies or other entities.

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