Share with your friends

UK: Residential property owned by foreign landlords, HMRC compliance project

UK: Residential property owned by foreign landlords

Letters are being sent to tenants occupying UK residential property owned by non-resident corporate landlords. The letters are in the form of a four-page questionnaire.


Related content

If no reply is received to the letter, HM Revenue & Customs (HMRC) will register the property for the “annual tax on enveloped dwellings” (ATED) and issue a tax determination to the offshore landlord.


HMRC’s goal is to establish whether rental income paid in respect of UK property that is owned by foreign owners has been or is correctly declared.

The four-page questionnaire asks for various details including (1) the name of the tenant, (2) the identity of the landlord/owner, (3) rent paid, (4) the date the property was acquired, (5) the name and address of the trust if owned by a trust, (6) the name and address of the settlor, and (7) a copy of the trust deed if held.

Possible options

Owners need to consider communicating with their agents or tenants that might be in receipt of the HMRC letters. Further in responding to the HMRC’s letter, owners may need to consider whether there are any broader tax risks associated with the structure that may require disclosure or amendment that could lead to failure to correct penalties (that start at 100% of the tax).

Read a November 2019 report prepared by the KPMG member firm in the UK

The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us


Want to do business with KPMG?


loading image Request for proposal