HMRC disclosure facility for non-resident landlords

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Letters are being sent during August to companies resident outside the UK that HMRC’s records show hold UK commercial property and have not registered for income tax or corporation tax in relation to these properties.

The letter requests the company to complete a certificate confirming whether the company needs to make a disclosure of unpaid tax.

If a disclosure is required, HMRC is directing recipients to its guidance on voluntary disclosures, unless the company has committed tax fraud, in which case it is directed to the contractual disclosure facility.

The letter also asks the recipient to consider whether they have any VAT liabilities in relation to those properties, or whether the transfer of asset abroad provisions might apply in relation to UK-resident individuals with an interest in the income or capital of the companies concerned.

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