Kate Gott Corporate Tax Director

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Kate Gott

Corporate Tax Director

Kate joined Wilson Wright in 2016, having predominantly worked within the UK’s top 10 accounting firms over the previous decade.

She is a chartered tax adviser specialising in advising businesses and their owners. She works for a wide range of clients, including companies, LLPs and partnerships.

Her areas of expertise include research and development tax credit work, both international and domestic tax efficient structuring, transfer pricing, and due diligence. Kate also has significant experience of working with private equity structures and professional service firms.

She works closely with her clients to ensure they keep up to date with their tax compliance obligations and are aware of tax planning opportunities and changes to the tax legislation that may affect them.

4 Nov 2022

HMRC has officially launched a campaign to uncover and target non-compliant offshore corporate owners of UK property.

HMRC has carried out a deep dive into the HM Land Registry records to unearth non-resident corporate interests in UK land. This has yielded far-reaching results as HMRC has discovered an array of non-resident corporate owners of UK property which it was previously unaware of. Their review has identified that many may not be meeting their UK tax obligations.

As HMRC seeks to differentiate the UK tax compliant from the non-UK tax compliant offshore corporates, the next step in this campaign will be to issue one of two letters depending on where the perceived non-compliance lies.

There is a letter which targets non-resident corporates with UK property interests, who may be required, but have not disclosed UK property income or who may be subject to the UK’s Annual Tax on Enveloped Dwellings (ATED).

This letter also advises that any UK-resident individuals with an interest in the income or capital derived from UK property, owned by a non-resident corporate are at risk of falling within the auspices of the Transfer of Assets Abroad (ToAA) legislation.

An alternative letter will be issued to non-resident corporates where HMRC finds evidence that suggests a disposal of UK residential property between 6 April 2015 and 5 April 2019 occurred, but the requisite Non-Resident Capital Gains Tax (NRCGT) return was not filed. Such offshore corporates may have also contravened wider tax compliance obligations, potentially amassing unsettled liabilities in relation to rental profits or earnings subject to ATED rules and charges.

If you have any concerns, or believe you may be impacted by the above, please get in touch with one of our advisers.