New anti-avoidance provisions designed to tax offshore property developers on their UK profits were introduced by Finance Act 2016 with effect from 5 July 2016. HMRC first published a technical note explaining these rules in March 2016

  • Offshore developers and dealers of UK land are subject to UK tax on their profits.
  • New rules apply to both UK resident and non-resident individuals and businesses and do not require a UK PE.
  • Measures effective from 5 July 2016. Anti-avoidance provisions in place since 17 March 2016.

For more details on these measures see our subscriber guide Profits from dealing in or developing UK land


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