Corporation Tax

Companies that own, develop or invest in property face a distinct set of corporation tax considerations, and the rules governing how property income, gains and costs are treated within a corporate structure are more detailed than those that apply to individual owners.

We advise companies, property investors and developers on corporation tax as it applies to property, providing clear and practical guidance that helps clients understand their position and manage their tax affairs effectively.

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A Considered Approach to Corporation Tax and Property

Holding property through a company introduces a different tax framework from individual ownership, one that affects how rental income is taxed, how gains on disposal are calculated, how financing costs are treated and how losses can be used. The corporation tax position does not sit in isolation either, as it interacts with decisions around ownership structure, profit extraction and longer-term strategy.

Our approach is to help clients understand how corporation tax applies to their property interests, identify where the corporate structure creates opportunities or complications, and ensure that the tax position is properly managed across the life of the investment, from acquisition through to disposal.

Decisions made at the outset of a property investment can have a lasting impact on the corporation tax position, and taking advice early is generally more effective than addressing issues once they have crystallised.

Who We Act For

We advise a range of clients on corporation tax matters connected to property, including property investment and development companies, trading businesses that own their premises, special purpose vehicles and holding structures used to acquire or manage property, and professional advisers supporting clients with corporate property interests.

Our advice is frequently delivered alongside solicitors and accountants as part of a wider advisory team, ensuring that the corporation tax position is properly integrated into transaction and investment planning.

Rental Income and Property Investment Companies

For companies deriving income from letting property, the starting point is understanding how that income is taxed within the corporation tax framework, what costs are deductible, and how the position interacts with other income and activities within the same corporate group.

We advise on the corporation tax treatment of rental income, including allowable deductions, the treatment of finance costs within a corporate structure, and the interaction between property income and other taxable activities.

A clear and properly maintained corporation tax position is particularly important for companies managing portfolios where income, costs and financing arrangements are spread across multiple properties or entities.

Property Disposals and Chargeable Gains

Gains arising on the disposal of property held within a company are subject to corporation tax rather than capital gains tax, and the rules governing how those gains are calculated and what reliefs are available differ from those that apply to individual owners.

We advise on the corporation tax treatment of property disposals, including the calculation of chargeable gains, the availability of reliefs, and the interaction between a property disposal and the wider tax position of the company.

Where a disposal forms part of a wider restructuring or exit strategy, we can help ensure that the transaction is approached in a way that is both commercially appropriate and tax efficient.

Development and Trading Activity

Companies involved in property development face a different corporation tax treatment from those holding property as a long-term investment, with development profits treated as trading income rather than chargeable gains and the timing of income recognition having a significant bearing on the overall tax position.

We advise on the corporation tax implications of property development activity, including the distinction between trading and investment, the treatment of development costs, and the interaction between development activity and other property interests held within the same corporate structure.

Understanding how development activity is characterised for tax purposes is essential to managing the corporation tax position effectively throughout the development cycl

Our Approach

Our role is to provide clear, practical corporation tax advice that is grounded in the specific circumstances of each client and their property interests, with a focus on ensuring that the tax position is correctly identified, properly managed and aligned with the wider commercial and investment strategy.

We work closely with solicitors, accountants and other advisers to ensure that corporation tax is considered as part of the overall approach to property ownership and investment, so that clients are not exposed to unexpected liabilities or compliance risk as their portfolio or business evolves.

Speak to Our Team

Corporation tax and property is an area where structure, timing and planning all have a direct bearing on the tax outcome, and where taking advice at the right stage can make a meaningful difference to the overall position.

If you are a company with property interests or would like to understand how corporation tax applies to a proposed transaction or investment, we would be happy to assist.

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Whether you need advice on a specific matter or wish to discuss how we can support your business or personal needs, we're here to help.

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