In 2022, the government introduced a requirement for overseas entities who own land in the UK to register with Companies House. The original deadline was 31 January 2023. The requirements do though also come with an annual review requirement members should not forget.
According to Companies House, any overseas entity that has had changes of ownership (and thus require verification) will need to be submit those details to Companies House by a UK regulated agent. Unlike the registration process, there is no option to submit a separate verification statement.
If there are no changes, the overseas entity can submit their own annual update form. Please note that changes to addresses, names and similar are included as requiring a reverification and will need to be completed by a UK regulated agent no more than three months prior to the date of the update statement.
The overseas entity will need to confirm one of the following statements:
- The entity has no reasonable cause to believe that anyone has become or ceased to be a registrable beneficial owner during the update period
- The entity has reasonable cause to believe that at least one person has become or ceased to be a registrable beneficial owner during the update period
i. The required information about each person who has become or ceased to be a registrable beneficial owner during the update period, or so much of that information as the entity has been able to obtain
ii. The date on which each of them became or ceased to be a registrable beneficial owner, if the entity has been able to obtain that information
The filing fee is £120 and a link to electronic form is here:
There may also well be cases where a company no longer has property in the UK and so is no longer required to be registered. Companies House have not provided any guidance on the method/person able to complete a removal application. They have only confirmed the expected application filing fee as £400 so far.
However, section 9 of the ECTEA does state that removal requires similar steps to filing an annual update, in terms of complying with the section 12 notice, confirming the status of beneficial owners and verifying any changes up to that point. Hence, one assumes this can only be undertaken by a UK registered agent.
*The views expressed are the author's and not ICAEW's.
