Direct tax treatment of property ownership

This subtopic covers the direct tax treatment (ie corporation tax, income tax and capital gains tax treatment) of owning freehold or leasehold property, primarily in the UK. There are a number of relevant considerations, including:

1. •

   whether the taxpayer is trading (ie dealing), or investing, in property

2. •

   the nature of the taxpayer (eg an individual, company or unit trust)

3. •

   the principles of computing income tax, corporation tax or capital gains tax (as appropriate) on rental income, and the proceeds of sale, from property

4. •

   the extent to which non-UK residents owning UK property are subject to direct taxation in the UK, and

5. •

   the application of the UK's anti-avoidance measures to property owners